FINAL SCOPING REPORT FOR THE PROPOSED JUNO 140 MW WIND ENERGY FACILITY, WESTERN CAPE
On behalf of
AMDA DEVELOPMENTS
July 2018
DEA REFERENCE NUMBER: 14/12/16/3/3/2/1074
Prepared By:
Arcus Consultancy Services South Africa (Pty) Limited
Office 220 Cube Workspace Icon Building Cnr Long Street and Hans Strijdom Avenue Cape Town 8001
T +27 (0) 21 412 1529 l E [email protected] W www.arcusconsulting.co.za
Registered in South Africa No. 2015/416206/07
Final Scoping Report Juno Wind Energy Facility
EXECUTIVE SUMMARY
INTRODUCTION AMDA Developments (Pty) Ltd are applying for environmental authorisation to construct the Juno Wind Energy Facility (WEF) generating a maximum of 140 MW and its associated infrastructure. Arcus Consultancy Services South Africa (Pty) Ltd (‘Arcus’) has been appointed by AMDA Developments as the independent environmental impact assessment practitioner (EAP). Arcus will conduct the Environmental Impact Assessment (EIA) process and the Basic Assessment (BA) process for the associated grid connection infrastructure, as required by the National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA), as amended. The proposed Juno WEF aims to generate and distribute electricity from renewable wind energy sources into the national grid by connecting the on-site substation with 132 kV power lines to the existing Eskom Juno substation located approximately 16 km north east of the proposed on-site substation. In order for this activity to commence a basic assessment process will need to be undertaken. This will be subjected to a separate application process and impact assessment. The development is proposed to construct a wind energy facility (WEF) and associated on site infrastructure. The project is expected to have a 25 year life span, but with possible refurbishment this could be extended if deemed feasible at the time. AMDA Developments is an international renewable energy company specialised in the development, construction and management of high-value projects in the energy and sustainability fields. Arcus is a specialist environmental consultancy providing environmental services to the renewable energy market. Arcus has advised on over 150 renewable energy projects in the United Kingdom and South Africa with environmental management and in-house specialist services. SITE LOCATION AND PROPOSED DEVELOPMENT DESCRIPTION The exact location of each turbine, and the routing of the powerlines will be determined during the EIA and BA processes and confirmed in the EIA phase, aided through the investigations of environmental, technical and financial constraints. The study area within which the project will be developed is located approximately 5 km northeast of Strandfontein in the Western Cape Province. The proposed Juno WEF will comprise up to 59 Siemens-Gamesa wind turbines with a generation capacity of either 2.6 or 3.4 MW (the exact number of turbines will be refined through the EIA process as specialist investigations and constraints and no go areas are defined). The 2.6 MW turbine model (SG 2.6-114) has a rotor diameter of 114 m, a hub height of 80 - 93 m and blade length of 56 m. The 3.4 MW turbine model (SG 3.4-132) has a rotor diameter of 132 m, a hub height of 84 - 114 m and blade length of 64.5 m. The combined generation capacity for the facility will not exceed 140 MW. An on-site switching station will be constructed as part of the Juno WEF, which will transfer the electricity generated by the WEF to the existing Eskom Juno substation. The on-site substation (including the switching station) will be approximately 200 m by 200 m in extent, contain transformers, switchgear, support structures, protection and metering equipment with a 2.4 m high enclosing wire mesh fence (two alternative locations have been proposed). The grid connection alternatives (overhead powerlines) run in a north-easterly direction from the proposed development site, crossing the Olifants River shortly before joining the existing Eskom Juno substation. The grid connection will form part of a separate application for authorisation through a basic assessment process. The proposed site is located on a flat to gently undulating coastal plain characterised by low shrubland vegetation. This Final Scoping Report aims to present and assess the initial proposed wind turbine layout and associated infrastructures. While a preliminary turbine layout has been provided, the precise location of each wind turbine, and the routing of the overhead power lines have not as yet been finalised and will be determined by the findings of the various specialists during the EIA Phase as well as other technical and financial constraints for this proposed site. ENVIRONMENTAL LEGISLATIVE REQUIREMENTS The EIA Regulations 2014 published in Government Notice (GN) No. R. 982, provide for the control of certain Listed Activities. These activities are listed in GN No. R. 983 (Listing Notice 1 – Basic Assessment), R. 984 (Listing Notice 2 – Scoping & EIA Process) and R. 985 (Listing Notice 3 – Basic Assessment) of 4
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December, and are prohibited to proceed until environmental authorisation has been obtained from the competent authority, in this case, the Department of Environmental Affairs (DEA). On 7 April 2017 in Government Gazette 40772 the Minister of Environmental Affairs published amendments in Government Notice (GN) Number R. 326 to the Environmental Impact Assessment (EIA) Regulations of 2014 that provide for the control of certain Listed Activities. These activities are listed in Listing Notice 1 (GN R327), Listing Notice 2 (GN R325) and Listing Notice 3 (GN R324). Activities triggered within Listing Notice 1 and 3 require Basic Assessment; activities within Listing Notice 2 require a Scoping & EIA Process. As the proposed Juno WEF development triggers Listed Activities in Listing Notices 1 – 3, a full Scoping and EIA process will be followed for this application. Listed Activities applicable to the proposed Juno WEF are presented in the table below. All potential impacts associated with these Listed Activities will be considered and assessed in this EIA. Applicable Listed Activities in terms of the NEMA LISTING NOTICE ACTIVITIES
LN 1 GN R3271 11 (i); 14; 19; 24 (ii); 48 (i) & 56 (ii). LN 2 GN R3252 1 & 15. LN 3 GN R3243 4; 12; 14; 18 & 23.
Depending on the final design of the Juno WEF, there may be a requirement for the following additional permits/ authorisations: Biodiversity Permits in terms of the National Environmental Management: Biodiversity Act (Act No 10 of 2004) (NEMBA); Waste Management License/s as required by the NEMA, Waste Act, 2008 (Act No. 59 of 2008); Mining Permits as required by the Minerals and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002) (MPRDA); and Water Use Licenses as required by the National Water Act, 1998 (Act No. 36 of 1998) (NWA). These permits will be applied for should the project be authorised and be selected as a preferred bidder. AREAS OF INITIAL INVESTIGATION A number of initial specialist investigations have been completed for this Final Scoping Report and their findings are included in Sections 7-15 of this document. Should further fields of study be identified as requiring further investigation during the Scoping Phase, usually through the public participation process, these will be considered for inclusion into the scope of the EIA. Each of the specialist assessments (geology, soils and agriculture, flora and fauna, avifauna, bats, freshwater and wetlands, noise, landscape and visual, cultural heritage, archaeology and palaeontology, and socio-economics) will follow a systematic approach to the identification and assessment of impacts, with the principal steps being: Description of existing environment/baseline conditions; Prediction of likely potential impacts, including cumulative impacts (both positive and negative); Assessment of likely potential impacts (positive and negative); Identification of appropriate mitigation measures; and Assessment of residual (potential) environmental impacts. The individual baseline descriptions and assessment methodologies are set out in Sections 7-15 of this report. The approaches are in line with legal requirements and industry guidelines and will make use of the considerable experience and expertise of the EAP and the specialists. PLANNING CONTEXT Spatial framework and strategic planning/policy documents that are the most relevant to this proposal on a national, provincial, metropolitan and local level were reviewed as part of this study. Planning policies
1 “Listing Notice 1 of the EIA Regulations, promulgated under Government Notice R983 of 4 December 2014, as amended by Government Notice R327 of 7 April 2017.” 2 “Listing Notice 2 of the EIA Regulations, promulgated under Government Notice R984 of 4 December 2014, as amended by Government Notice R325 of 7 April 2017.” 3 “Listing Notice 3 of the EIA Regulations, promulgated under Government Notice R985 of 4 December 2014, as amended by Government Notice R324 of 7 April 2017.”
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are listed in Section 4.7 of the Draft Scoping Report (DSR) (this report – Volume 1) and in further detail in the Social Scoping Report, which is included in Volume 2. It is established that policy supports the development of renewable energy at all levels of governance. The intent of local, provincial and national policies is to address energy supply issues and to promote economic growth in South Africa. The following policy and planning documents were assessed: National National Energy Act (2008); White Paper on the Energy Policy of the Republic of South Africa (December 1998); White Paper on Renewable Energy (November 2003); Integrated Resource Plan (IRP) for South Africa (2010-2030); The National Development Plan (2011); New Growth Path Framework (2010); National Infrastructure Plan (2012).
Provincial and local White Paper on Sustainable Energy for the Western Cape Province (2010); The Western Cape Provincial Strategic Plan 2014-2019 (2014); The Western Cape Land Use Planning Act, 2014; The Western Cape Provincial Spatial Development Framework (2014 Revision); The Western Cape Climate Change Response Strategy (2014); The Western Cape Infrastructure Framework (2013); The Western Cape Green Economy Strategy Framework (2013); The One Cape 2040 Strategy (2012); The Western Cape Amended Zoning Scheme Regulations for Commercial Renewable Energy Facilities (2011); The Western Cape Draft Strategic Plan (2010); The Strategic Initiative to Introduce Commercial Land Based Wind Energy Development to the Western Cape – Towards a Regional Methodology (2006); The Guidelines for the Management of Development on Mountains, Hills and Ridges in the Western Cape (2002); West Coast District Municipality Integrated Development Plan (2015/2016 Review); West Coast District Municipality Spatial Development Framework (2017); Matzikama Municipality Spatial Development Framework (2014); Matzikama Municipality Integrated Development Plan (2012-2017).
NEED AND DESIRABILITY The Guideline for Need and Desirability released by the DEA in 2017 was used to assess the need and desirability of the proposed Juno WEF. According to the DEA guideline4: “Need and desirability is based on the principle of sustainability, set out in the Constitution and in NEMA, and provided for in various policies and plans, including the National Development Plan 2030 (NDP). Addressing the need and desirability of a development is a way of ensuring sustainable development – in other words, that a development is ecologically sustainable and socially and economically justifiable – and ensuring the simultaneous achievement of the triple bottom-line.” Section 4 of this report describes need and desirability for this development in detail, and provides an explanation as to why wind energy can be considered as an alternative to meeting the need for increased electricity demand over other sources of generation such as fossil fuels. Summarily, these reasons include: Positive impact on climate change; Overcoming the country’s energy constraints; Diversification and decentralisation of supply; Reduced costs of energy; and Positive economic development including job creation. With regards to the proposed Juno WEF, wind resource in the area is competitive by national and international comparison. ALTERNATIVES
4DEA (2017), Guideline on Need and Desirability, Department of Environmental Affairs (DEA), Pretoria, South Africa ISBN: 978-0-9802694-4-4
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Alternatives are different means of meeting the general purpose and need of a proposed development and may include alternative sites, alternative layouts or designs, alternative technologies and the “no development” or “no go” alternative. Section 6 of the FSR provides an outline of the site selection process that was undertaken in relation to the proposed Juno WEF. Analysis of preliminary site considerations were investigated to evaluate the project site location. These factors included: Grid connection options and capacity availability on the existing national grid; The feasibility of site access; Technical construction issues such as geological conditions and topography; and Preliminary high level environmental considerations. The proposed Juno WEF is the preferred site, based on the anticipated wind resource (high wind speeds), proximity to existing grid infrastructure, land availability, minimum technical constraints from a construction perspective and the absence of high level environmental issues at the monitoring and pre- feasibility stage. These will be further investigated during the EIA process. Following the selection of a suitable site, consideration is given to the design and layout of the WEF within the site boundaries. It is important that wind turbines are sited in the optimum position to maximise the wind energy yield whilst minimising environmental impacts. Various wind turbine designs and layouts will be considered for the site in order to maximise the electricity generation capacity and efficiency with minimal environmental impact. A number of alternatives for the grid connection were considered, including alternative voltages for the connection. Three alternative routes for the connection of the WEF to the existing Eskom substation will be assessed during the separate basic assessment process for environmental authorisation of the grid connection. An additional alternative that will be considered is the “No Development Scenario” or “No-Go Option” which assumes that the proposed development does not proceed. It is equivalent to the future baseline scenario in the absence of the proposed development, and this situation is also assessed. ENVIRONMENTAL IMPACT ASSESSMENT PROCESS The EIA process is a decision-making tool with the specific aim of selecting an option that will provide an appropriate balance between the benefits of a proposed development and the potential adverse environmental impacts. The EIA process is designed to identify activities which may have a detrimental effect on the environment, and proposed mitigation measures to minimise or eliminate these potential impacts. Should this balance be achieved the competent authority will issue an environmental authorisation, with conditions, for the development to proceed. Scoping Phase Pre-application meeting with DEA; Coordinate specialist studies, including acting as intermediary between the specialists and AMDA regarding the approach for the scoping and EIA process, e.g. advising on planned monitoring and methodologies; Management of specialists including coordination of scoping phase site visits; Compilation and submission of the application form to DEA; Public Participation Process (PPP) initiated through the preparation of Site Notices, Adverts, call for I&AP registration; Liaising between the specialists and AMDA regarding the design of the Development throughout the scoping phase; Ensure feasible and reasonable alternatives are identified and selected for more detailed assessments; Digitising field survey data supplied by the specialists to ensure a quality, consistent output; Mapping of constraints to inform the design of the project; Production of the draft and final scoping reports; Management of PPP, hosting a public meeting (scoping phase), compiling a comments and response report; and Providing on-going advice to the application of appropriate environmental impact assessment methodologies and developing mitigation techniques. Scoping Phase Deliverables Compilation and submission of the Environmental Authorisation Application Form to DEA, Compilation and submission of Draft Scoping Report (DSR), including incorporation of specialist studies; and
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Compilation and submission of the Final Scoping Report (FSR) including evidence of the Public Participation Process and incorporation of the comments and response reports. EIA Process for the Juno Wind Energy Facility Arcus would act as the EAP leading the project management of the EIA through to submission of the consent applications. The key role of the EAP is to coordinate the specialist inputs, draft the required reports and application forms, and act as an intermediary between the specialists and AMDA to aid the design of a successful project. Arcus would liaise with the DEA throughout the application process to ensure information is supplied as required and the application progresses. Throughout this process, Arcus would ensure that AMDA remain informed of the findings of the studies and likely requirements for monitoring (e.g. during pre-construction and post construction), and proposed mitigation strategies which may inform the development design or operational requirements. Arcus would encourage on-going dialogue between the specialists and AMDA so as to allow decisions to be informed about the potential project risks and work towards a successful development, balancing the inputs of the parties involved. Management of specialists including coordination of additional site visits if necessary; Coordinating the specialist input into the draft environmental impact assessment report (Draft EIA Report), providing ongoing advice to the application of EIA methods and developing mitigation techniques; Management of PPP including hosting a public meeting (EIA phase), compiling comments and response reports; Digitising field survey data supplied by the specialists to ensure a quality, consistent output; Mapping of constraints to inform the design of the project; Coordinating the production of the draft and final Environmental Impact Assessment Report (Final EIA Report) and EMPr; and Management of the Decision of Authorisation, including notifying I&APs. EIA Deliverables: Compilation and submission of Application Form to DEA; Compilation and submission of a Draft Environmental Impact Assessment Report (Draft EIA Report) and Draft Environmental Management Plan including incorporation of EIA-phase specialist studies; and Compilation and submission of Final Environmental Impact Assessment Report (Final EIA Report) and Environmental Management Plan, including incorporation of EIA-phase specialist studies and evidence of Public Participation Process. SUMMARY OF FINDINGS The Final Scoping Report has captured the key and/or scoped issues and impacts for this proposed development by taking into account the findings of the public participation process as well as the specialists’ study reports. The specialist reports document anticipated environmental impacts that may be experienced within both the biophysical and social environments. The impacts have been preliminarily assessed, as is required by the NEMA 2014 EIA Regulations as amended by GN R326 of 2017. All specialist reports are included in Volume 2 of this report. The Soils and Agricultural Study noted that the prevailing potential of the soils on the sites for rain-fed cultivation throughout most of the area is low to very low. No further investigation is thus required by the Soil Specialist. All the remaining specialists, however, are to conduct site visits where necessary, and investigate and assess the proposed development in more detail during the EIA Phase. A Plan of Study for the EIA Phase is included in Section 18 of this document. The following initial observations can be made from the findings of the specialists’ investigations and preliminary assessments: At this preliminary Scoping level stage of the process, all potential impacts of high or medium negative significance can be mitigated to medium or low negative significance; No potential impacts remain at high negative post mitigation; The Social Scoping Report has found that the establishment of WEFs in this area is supported by national, provincial and local policies and planning documents. During this Scoping phase the specialists’ assessments have identified areas of further investigation and the project can proceed into the EIA phase. All identified potential impacts are to be investigated and
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assessed in further detail during the EIA Phase, together with any additional impacts or concerns raised during the public participation process.
The Final Scoping Report is available for review at the Vredendal Public Library,
Strandfontein Municipal Hall and on the Arcus website.
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ABBREVIATIONS, ACRONYMS AND UNITS BGIS Biodiversity Geographic Information LSA Late Stone Age System MSA Middle Stone Age CARA Conservation of Agricultural MW Megawatt Resources, 1983 (Act No. 43 of 1983) NDP National Development Plan CBA Critical Biodiversity Area NEMA National Environmental Management CCRS Climate Change Response Strategy Act, 1998 (Act No. 107 of 1998) CSP Concentrated Solar Power NFEPA National Freshwater Ecosystem DAFF Department of Agriculture, Forestry Priority Area and Fisheries NHRA National Heritage Resources Act, dB Decibel 1999 (Act No. 25 of 1999) DEA Department of Environmental Affairs NSD Noise-sensitive Developments (National) NWA National Water Act, 1998 (Act No. 36 DoE Department Of Energy of 1998) DSR Draft Scoping Report PES Present Ecological State DWS Department of Water and Sanitation PGDS Provincial Growth and Development Strategy EAP Environmental Assessment Practitioner PICC Presidential Infrastructure Coordinating Committee ECA Environment Conservation Act, 1989 No. 73 of 1989) PPA Power Purchase Agreement EIA Environmental Impact Assessment PPP Public Participation Process EIR Environmental Impact Report PSDF Provincial Spatial Development Framework EMPr Environmental Management Programme PSEIA Plan of Study for EIA ESA Ecological Support Area PV Solar photovoltaic ESA Early Stone Age RBS Revised Balanced Scenario Eskom Eskom Holdings SOC Limited RE Renewable Energy EWT Endangered Wildlife Trust REIPPPP Renewable Energy Independent Power Producer Procurement FSR Final Scoping Report Programme GHG Greenhouse Gas RSH Rotor Swept Height GIS Geographical Information Systems
GNR Government Notice Regulation SABAAP South African Bat Assessment GPS Global Positioning System Advisory Panel HDI Historically Disadvantaged Individuals SABS South African Bureau of Standards HIA Heritage Impact Assessment SAHRA South African Heritage Resources Agency HV High Voltage SAHRIS South African Heritage Resources Hz Hertz Information System I&AP Interested and Affected Party SANBI South African National Biodiversity IDP Integrated Development Plan Institute IEM Integrated Environmental SANRAL South African National Roads Agency Management Limited IPP Independent Power Producer SANS South African National Standards IRP Integrated Resource Plan SCADA Supervisory Control and Data Acquisition kV Kilovolt SDF Spatial Development Framework kWh Kilowatt Hours Arcus Consultancy Services South Africa (Pty) Ltd AMDA Developments July 2018 Page 8 Final Scoping Report Juno Wind Energy Facility
SHEQ Safety Health Environment and Quality SIA Social Impact Assessment SIPS Strategic Integrated Projects SKA Square Kilometre Array Project WEF Wind Energy Facility WHO World Health Organisation WTG Wind Turbine Generator WULA Water Use License Application
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GLOSSARY OF TERMS ‘Do nothing’ alternative or The ‘do nothing’ alternative, or ‘no go’ option is the option of not ‘no-go option’ undertaking the proposed activity or any of its alternatives. The ‘do nothing’ alternative also provides the baseline against which the impacts of other alternatives should be compared. Ambient noise The all-encompassing sound at a point being composed of sounds from many sources both near and far. It includes the noise from the noise source under investigation. Ambient sound level The level of the ambient sound indicated on a sound level meter in the absence of the sound under investigation (e.g. sound from a particular noise source or sound generated for test purposes). Ambient sound level as per Noise Control Regulations. Amplitude modulated sound A sound that noticeably fluctuates in loudness over time. Archaeology Remains resulting from human activity which are in a state of disuse and are in or on land and which are older than 100 years, including artefacts, human and hominid remains and artificial features and structures. Attenuation Term used to indicate reduction of noise or vibration, by whatever method necessary, usually expressed in decibels. Broadband noise Spectrum consisting of a large number of frequency components, none of which is individually dominant. Calcrete A soft sandy calcium carbonate rock related to limestone which often forms in arid areas. Cultural landscape The combined works of people and natural processes as manifested in the form of a landscape Cumulative impacts Impacts that result from the incremental impact of the proposed activity on a common resource when added to the impacts of other past, present or reasonably foreseeable future activities Cut-in speed The minimum wind speed at which the wind turbine will generate usable power. Cut-out speed The wind speed at which shut down occurs. Early Stone Age The archaeology of the Stone Age between 700 000 and 2500 000 years ago. Environmental management An operational programme that organises and co-ordinates mitigation, programme (EMPr) rehabilitation and monitoring measures in order to guide the implementation of a proposal and its ongoing maintenance after implementation. Fossil: Mineralised bones of animals, shellfish, plants and marine animals. A trace fossil is the track or footprint of a fossil animal that is preserved in stone or consolidated sediment. Generator The generator is what converts the turning motion of a wind turbine's blades into electricity Heritage That which is inherited and forms part of the National Estate (Historical places, objects, fossils as defined by the National Heritage Resources Act 25 of 1999. Holocene The most recent geological time period which commenced 10 000 years ago. Late Stone Age The archaeology of the last 20 000 years associated with fully modern people. Midden A pile of debris, normally shellfish and bone that have accumulated as a result of human activity. Middle Stone Age The archaeology of the Stone Age between 20-300 000 years ago associated with early modern humans. Miocene A geological time period (of 23 million - 5 million years ago). Nacelle The nacelle contains the generator, control equipment, gearbox and anemometer for monitoring the wind speed and direction. Palaeontology Any fossilised remains or fossil trace of animals or plants which lived in the geological past, other than fossil fuels or fossiliferous rock intended for industrial use, and any site which contains such fossilised remains or trace. Palaeosole An ancient land surface. Pleistocene A geological time period (of 3 million – 20 000 years ago). Pliocene A geological time period (of 5 million – 3 million years ago).
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Rotor The portion of the wind turbine that collects energy from the wind is called the rotor. The rotor converts the energy in the wind into rotational energy to turn the generator. The rotor has three blades that rotate at a constant speed of about 15 to 28 revolutions per minute (rpm). Structure (historic) Any building, works, device or other facility made by people and which is fixed to land, and includes any fixtures, fittings and equipment associated therewith. Protected structures are those which are over 60 years old. Tower The tower supports the rotor, and is constructed from tubular steel and/or concrete. The nacelle and the rotor are attached to the top of the tower. The tower raises the wind turbine so that its blades safely clear the ground in order to reach the stronger winds at higher elevations. Large modern wind turbines are usually mounted on towers ranging from 80 to 130 m tall. The tower must be strong enough to support the wind turbine and to sustain vibration, wind loading and the overall weather elements for the lifetime of the wind turbine. Wind rose The diagrammatic representation of joint wind speed and direction distribution at a particular location. The length of time that the wind comes from a particular sector is shown by the length of the spoke, and the speed is shown by the thickness of the spoke.
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DEPARTMENT OF ENVIRONMENTAL AFFAIRS INFORMATION REQUIREMENTS FOR WIND FARM APPLICATIONS
The Department of Environmental Affairs’ requirements for information for all applications for Wind Energy Facilities (WEFs) is included in this section of the report. Where this information is not provided in the tables below, the location of where it can be found in the report is indicated. Should the information not be available at this stage of the EIA process (Scoping phase), it is indicated that it shall be documented during the EIA phase.
Table A: Information Requirements – WEF and Grid Connection General Site Information Description Comment / Description
Descriptions of all affected farm The Remaining Extent of Farm De Boom No. 273, 4682.1440Ha portions 21 digit Surveyor General codes of C07800000000027300000 all affected farm portions Copies of deeds of all affected farm T18219/1990 portions Photos of areas that give a visual Will be provided by the visual specialist during the EIA Phase. perspective of all parts of the site Photographs from sensitive visual Will be provided by the visual specialist during the EIA Phase. receptors (tourism routes, tourism facilities, etc.)
Wind plant design specifications including:
Type of technology Onshore Wind
Structure height (Tip Height) Maximum of 180 m tip height
Surface area to be covered TOTAL ESTIMATED MAXIMUM SURFACE AREA COVERED – (including associated infrastructure 87.6 HECTARES, disaggregated below. such as roads) [Note - this is a very conservative estimate]
Turbine bases including crane pad hard standings = 0.4 hectares each maximum. 59 Turbines totals 23.6 Ha.
Substation, Control Building and Laydown areas - 4 hectares.
Internal Roads – 12m wide, approx. 50km in length maximum – 60 Ha.
Structure orientation Vertical towers with 3 blades attached
Laydown area dimensions Permanent laydown area approx. 1 Ha. Additional temp laydown (Construction period and Operation) area for construction another 1 Ha. Generation capacity of the facility as 140 MW a whole at delivery points Construction Phase
Batching Plants To be decided, depending on technical and economic feasibility of concrete-made towers. Fuel Storage Laydown areas, construction compound will be used temporarily.
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Description Comment / Description
Borrow Pits Most of the stone will be acquired from the turbine foundations.
Water Supply Borehole or imported to be determined through the EIA phase, the source of the water. Employment opportunities 200 jobs during the construction phase of the development. Low Semi-skilled skilled Duration of Construction phase From 1 year to 2 years on EPC agreement
Estimate total expenditure for 2.5 billion ZAR (2018) construction phase Opportunities for skills development Multiple opportunities including on-site training with EPC contractor and training and turbine manufacturer. Details to be decided should the project be awarded preferred bidder. Description of typical activities Creating concrete foundations for the WTG, assembling the WTG on associated with construction phase, site at ground level, erecting blades with large cranes, widening on site activities, how will the large existing paths or creating new, creating a new electrical substation, components be transported to site laying electrical wiring along paths, new over-head power line from and assembled switching station to Eskom Juno substation. Traffic assessment will be completed during the EIA phase to determine the best route for any components to be transported to site. The size of the vehicle’s needed to Abnormal loads to carry blade sections up to 64.5 m in length, and transport the components and the tower sections (tower design to be decided depending on the routes that will be used to transport feasibility of utilising concrete or steel). the large components to site Operation Phase
Employment opportunities 30 jobs
Community Development Community Development Plan to be commissioned. Dedicated Community Development Manager will be appointed to liaise with local communities. Water supply Small amount of water for ablution facilities for up to 30 staff (drinking water etc.) from borehole – to be decided by Dept. Water Affairs, should there be water available for use. Maintenance Inspections of towers, nacelles and blades; test of SCADA systems and gearboxes. Electrical maintenance of new IPP substation. Typical activities associated with Routine inspections of blades (quarterly access for small team). operational phase Access for Eskom. Occasional blade or gearbox replacement of 10% of machines (expected after year 10 only). Opportunities for skills development Ongoing for 20 years with chosen turbine manufacturer including and training probable opportunities for training of RSA Citizens abroad – dependant on location and origin of the manufacturer - to be decided. Lifespan of operation phase 20 years
Other
Plan for WEF at Decommissioning – Repowering is desirable if economic situation after 20 years is repower or decommission? suitable; if not decommission. Community trust for the area? Yes – to be established
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Table B: Information Requirements – WEF Technical Details Component Description/Dimensions
Location of the site West Coast District Municipality, Western Cape
Total site area 4,682 Ha
Facility Area 4,682 Ha
Number of Turbines and MW of Turbine This will depend on the generation capacity of the selected turbine. The turbines specified in the provisional technical specifications are Gamesa (Siemens) of either 2.6 or 3.4 MW. Up to 59 turbine positions will be built depending on size and final WEF capacity. Hub Height Up to 114 m – depending on selected turbine
Blade Length Up to 64.5 m – depending on selected turbine
Rotor Diameter Up to 132 m – depending on selected turbine
Area occupied by inverter transformer New IPP substation: 200 x 200 meters substation, stations/substations transformers and ops building (two alternative locations) Maximum 4 hectares Capacity of on-site substation / switching 33/132 kV station Area occupied by both permanent and 1 Ha each construction laydown areas Operations and maintenance buildings (O&M 1 Ha building) with parking area Length of internal roads (construction and 50 km maximum operation) Width of internal roads (construction and 6 - 12 m including road reserve. operation) Proximity to grid connection (km) 16 km Connecting to? Height of fencing 2.4 m only at new IPP substation 2.4 m for temporary camp base (to be studied) Type of fencing Wired mesh / chain link fence not electrified
Security Lighting Security lights on top of wind turbines if SACAA requires Navigation Lights
Table D: DEA Information Requirements - Site Maps and GIS Information Site Maps and GIS Information Section of this Report
All maps/information layers must also be provided in ESRI Shapefile format.
All affected farm portions must be indicated. Figure 3.1 Proposed Site Development Plan
The exact site of the application must be indicated (the areas Figure 1.1 Site Location that will be occupied by the application). Figure 3.1 Proposed Site Development Plan
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Site Maps and GIS Information Section of this Report
A status quo map/layer must be provided that includes the following: Current use of land on the site including:
Buildings and other structures Figure 12.1 Potential Noise-sensitive Developments To be produced during EIA phase
Agricultural fields To be produced during the EIA phase
Grazing areas To be produced during the EIA phase
Natural vegetation areas (natural veld not cultivated for the Figure 8.1 Vegetation Types preceding 10 years) with an indication of the vegetation To be determined during EIA phase quality as well as fine scale mapping in respect of Critical Biodiversity Areas and Ecological Support Areas
Critically endangered and endangered vegetation areas that Figure 8.3 Critical Biodiversity Areas occur on the site map for the study area None identified by specialist at this scoping stage.
Bare areas which may be susceptible to soil erosion To be produced during the EIA phase.
Cultural historical sites and elements To be produced during the EIA phase.
Rivers, streams and water courses Figure 11.1 Watercourses in the site vicinity
Ridgelines and 20 m continuous contours with height Figure 7.1 Soil map and soil references in the GIS database observation points Ridgelines and contours to be produced during the EIA phase.
Fountains, boreholes, dams (in-stream as well as off-stream) NFEPA wetlands and artificial dams and reservoirs shown in Figure 11.1 Quaternary Catchments and Mainstem Rivers within the Region. Map of reservoirs, fountains and boreholes to be produced during the EIA phase.
High potential agricultural areas as defined by the Department No high potential agricultural areas of Agriculture, Forestry and Fisheries have been identified by the specialist.
Buffer zones (also where it is dictated by elements outside the Figure 17.1 Preliminary Environmental site): Constraints Map 500 m from any irrigated agricultural land Figure 12.1 Potential Noise-Sensitive Developments 1 km from residential areas
Indicate isolated residential, tourism facilities on or within 1 Figure 12.1 Potential Noise-Sensitive km of the site Developments
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Site Maps and GIS Information Section of this Report
A slope analysis map/layer that include the following slope To be produced during EIA phase ranges: Less than 8% slope (preferred areas for turbines and infrastructure) Between 8% and 12% slope (potentially sensitive to turbines and infrastructure) Between 12%and 14% slope (highly sensitive to turbines and infrastructure) Steeper than 18% slope (unsuitable for turbines and infrastructure)
A map/layer that indicate locations of birds and bats including Figure 10.1 Preliminary Bat Sensitivity roosting and foraging areas Map Bird sensitivity map to be produced during the EIA phase; subsequent to completion of bird monitoring
A site development proposal map(s)/layer(s) that indicate: Figure 3.1 Proposed Site Development Plan Turbine positions Details to be determined during the Foundation footprint EIA phase. Permanent laydown area footprint Construction period laydown footprint Internal roads indicating width (construction period width and operation period width) and with numbered sections between the other site elements which they serve (to make commenting on sections possible).
River, stream and water crossing of roads and cables To be produced during the EIA phase indicating the type of bridging structures that will be used.
Substation(s) and/or transformer(s) sites including their Figure 3.1 Proposed Site Development entire footprint. Plan
Cable routes and trench dimensions (where they are not along To be produced during EIA phase internal roads) Connection routes to the distribution/transmission network (the connection must form part of the EIA even if the construction and maintenance thereof will be done by another entity such as ESKOM).
Cut and fill areas at turbine sites along roads and at To be produced during the EIA phase substation/transformer sites indicating the expected volume of each cut and fill
Borrow pits To be produced during the EIA phase
Spoil heaps (temporary for topsoil and subsoil and To be produced during the EIA phase. permanently for excess material) Buildings including accommodation
Table E: Legislative Requirements for the Content of this Final Scoping Report
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Location in Scoping EIA Regulations Appendix 2 Requirements Report
2 (a) details of- Section 1.4.1 (i)the EAP who prepared the report; and Appendix A –Curriculum Vitae (ii) the expertise of the EAP, including a curriculum vitae; of EAP (b) the location of the activity, including- Figure 1.1 Site Location (i) the 21 digit Surveyor General code of each cadastral land parcel; Table 3.1 Property Details (ii) where available, the physical address and farm name; Figure 3.1 Proposed Site (iii) where the required information in items (i) and (ii) is not available, the co- Development Plan ordinates of the boundary of the property or properties; Section 3.2. (c) a plan which locates the proposed activity or activities applied for at an Figure 3.1 Proposed Site appropriate scale, or, if it is- Development Plan (i) a linear activity, a description and coordinates of the corridor in which the Grid coordinates for the proposed activity or activities is to be undertaken; or preferred corridor will be (ii) on land where the property has not been defined, the coordinates within supplied during the EIA which the activity is to be undertaken; phase. (d) a description of the scope of the proposed activity, including- Section 3 (i) all listed and specified activities triggered; Table 5.1 (ii) a description of the activities to be ·undertaken, including associated structures and infrastructure; (e) a description of the policy and legislative context within which the Section 5 development is proposed including an identification of all legislation, policies, plans, guidelines, spatial tools, municipal development planning frameworks and instruments that are applicable to this activity and are to be considered in the assessment process; (f) a motivation for the need and desirability for the proposed development Section 4 including the need and desirability of the activity in the context of the preferred location; (h) a full description of the process followed to reach the proposed preferred Section 6 activity, site and location within the site, including- (i) details of all the alternatives considered; (ii) details of the public participation process undertaken in terms of regulation Section 16 41 of the Regulations, including copies of the supporting documents and inputs; (iii) a summary of the issues raised by interested and affected parties, and an Section 16 indication of the manner in which the issues were incorporated, or the reasons for not including them; (iv) the environmental attributes associated with the alternatives focusing on Sections 7 - 15 the geographical, physical, biological, social, economic, heritage and cultural aspects; (v) the impacts and risks identified for each alternative, including the nature, Sections 7 - 15 significance, consequence, extent, duration and probability of the impacts, including the degree to which these impacts- (aa) can be reversed; (bb) may cause irreplaceable loss of resources; and (cc) can be avoided, managed or mitigated; (vi) the methodology used in determining and ranking the nature, significance, Section 2 consequences, extent, duration and probability of potential environmental Section 17.3 impacts and risks associated with the alternatives; (vii) positive and negative impacts that the proposed activity and alternatives Sections 7 - 15 will have on the environment and on the community that may be affected
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Location in Scoping EIA Regulations Appendix 2 Requirements Report focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects; (viii) the possible mitigation measures that could be applied and level of Sections 7 - 15 residual risk; (ix) the outcome of the site selection matrix; Section 6 (x) if no alternatives, including alternative locations for the activity were Section 6 investigated, the motivation for not considering such and (xi) a concluding statement indicating the preferred alternatives, including Section 6 preferred location of the activity; (i) a plan of study for undertaking the environmental impact assessment Section 18 process to be undertaken, including- (i) a description of the alternatives to be considered and assessed within the preferred site, including the option of not proceeding with the activity; (ii) a description of the aspects to be assessed as part of the environmental impact assessment process; (iii) aspects to be assessed by specialists; (iv) a description of the proposed method of assessing the environmental aspects, including a description of the proposed method of assessing the environmental aspects including aspects to be assessed by specialists; (v) a description of the proposed method of assessing duration and significance; (vi)an indication of the stages at which the competent authority will be consulted; (vii) particulars of the public participation process that will be conducted during the environmental impact assessment process; and (viii) a description of the tasks that will be undertaken as part of the environmental impact assessment process; (ix) identify suitable measures to avoid, reverse, mitigate or manage identified impacts and to determine the extent of the residual risks that need to be managed and monitored. j) an undertaking under oath or affirmation by the EAP in relation to- Page xviii (i) the correctness of the information provided in the report; Appendix A –Commissioner of (ii) the inclusion of comments and inputs from stakeholders and interested and Oaths of EAP affected parties; and (iii) any information provided by the EAP to interested and affected parties and any responses by the EAP to comments or inputs made by interested or affected parties; k) an undertaking under oath or affirmation by the EAP in relation to the level Section 19 of agreement between the EAP and interested and affected parties on the plan of study for undertaking the environmental impact assessment;
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ENVIRONMENTAL ASSESSMENT PRACTIONER DECLARATION OF INDEPENDENCE This Final Scoping Report has been commissioned by AMDA Developments (Pty) Ltd to conduct the Environmental Impact Assessment (EIA) process for the WEF and the Basic Assessment (BA) process for the associated grid connection infrastructure, as required by the 2014 EIA Regulations (as amended by GN R 326 of 2017) under the National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) (‘the Regulations’). In compiling this report, the authors comply with the general requirements for Environmental Assessment Practitioners (EAPs) as set out below in the Regulations: “General requirements for EAPs and specialists: (1) An EAP and a specialist, appointed in terms of regulation 12(1) or 12(2), must— (a) be independent; (b) have expertise in conducting environmental impact assessments or undertaking specialist work as required, including knowledge of the Act, these Regulations and any guidelines that have relevance to the proposed activity; (c) ensure compliance with these Regulations; (d) perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the application; (e) take into account, to the extent possible, the matters referred to in regulation 18 when preparing the application and any report, plan or document relating to the application; and (f) disclose to the proponent or applicant, registered interested and affected parties and the competent authority all material information in the possession of the EAP and, where applicable, the specialist, that reasonably has or may have the potential of influencing— (i) any decision to be taken with respect to the application by the competent authority in terms of these Regulations; or (ii) the objectivity of any report, plan or document to be prepared by the EAP or specialist, in terms of these Regulations for submission to the competent authority; unless access to that information is protected by law, in which case it must be indicated that such protected information exists and is only provided to the competent authority.”
Ashlin Bodasing
Environmental Assessment Practitioner
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TABLE OF CONTENTS
1 INTRODUCTION ...... 1 1.1 Aims and Purpose of this Report ...... 1 1.2 Overview of the Proposed Development ...... 1 1.3 Project Proponent ...... 2 1.4 The Environmental Impact Assessment Project Team...... 2 1.4.1 Environmental Assessment Practitioners (EAPs) ...... 2 1.4.2 Specialists ...... 2 1.5 Assumptions and Limitations ...... 3 1.6 Structure of this Report ...... 3 1.7 Comments on Draft Scoping Report from the Department of Environmental Affairs ...... 4 1.8 Amendments from Draft to Final Scoping Report ...... 7
2 SCOPE OF WORK AND SCOPING PHASE METHODOLODY ...... 9 2.1 Scoping Phase Public Participation Process (PPP)...... 10 2.1.1 Pre-Scoping...... 10 2.1.2 Scoping Phase ...... 10 2.2 Specialist Scoping Assessments ...... 11 2.2.1 Baseline Description ...... 11 2.2.2 Prediction of Potential Impacts ...... 11 2.2.3 Assessment of Potential Impacts ...... 11 2.2.4 Mitigation ...... 12 2.2.5 Residual Impacts ...... 12 2.2.6 Cumulative Impact Assessment ...... 12 2.3 Contents of the Scoping Report ...... 12
3 DESCRIPTION OF THE PROPOSED DEVELOPMENT ...... 14 3.1 How Does Wind Energy Generation Work ...... 14 3.2 Site Description and Location of the Proposed Development ...... 14 3.3 Wind Energy Facility (WEF) Components ...... 15 3.3.1 Turbines ...... 15 3.3.2 Turbine Power Output and Transformers ...... 15 3.3.3 Electric Cabling and On-site Substation...... 15 3.3.4 Hard Stand Areas ...... 16 3.3.5 Laydown Areas ...... 16 3.3.6 Access ...... 16 3.3.7 Ancillary Equipment ...... 16 3.4 Transportation of Equipment to Site ...... 16 3.5 Description of the Construction Phase of the WEF ...... 17
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3.6 Description of the Operation Phase of the WEF ...... 17 3.6.1 Routine Servicing ...... 17 3.6.2 Unscheduled Maintenance ...... 18 3.7 Description of the Decommissioning Phase of the WEF...... 18 3.8 The Grid Connection Associated with the WEF ...... 18
4 NEED AND DESIRABILITY OF THE PROPOSED DEVELOPMENT ...... 19 4.1 Wind Resource at Juno WEF ...... 37 4.2 Wind Energy Facilities Contribution to Mitigating Climate Change ...... 37 4.3 Diversification and Decentralisation of Supply ...... 38 4.4 Reduced Cost of Energy ...... 38 4.5 Economic Development and Job Creation ...... 39 4.6 Policies in Support of Renewable Energy ...... 40 4.7 Need and Desirability Conclusion ...... 40
5 ENVIRONMENTAL LEGISLATION ...... 40 5.1 The National Environment Management Act, 1998 (Act 107 of 1998) ...... 40 5.2 The National Heritage Resources Act, 1999 (Act No. 25 of 1999) ...... 45 5.3 Subdivision of Agricultural Land Act, 1970 (Act No. 70 of 1970) ...... 45 5.4 Conservation of Agricultural Resources, 1983 (Act No. 43 of 1983) ...... 46 5.5 The Environment Conservation Act, 1989 (Act No.73 of 1989), the National Noise Control Regulations: GN R154 of 1992 ...... 46 5.6 National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) ...... 46 5.7 National Water Act, 1998 (Act No. 36 of 1998) ...... 46 5.8 National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004) – Threatened or Protected Species List ...... 47 5.9 The Nature and Environmental Conservation Ordinance No. 19 of 1974 .... 47 5.10 Additional Relevant Legislation...... 47 5.11 Conventions and Treaties ...... 47 5.11.1 The Paris Agreement (2016) ...... 47 5.11.2 The Convention on Biological Diversity (CBD) (1993) ...... 48 5.11.3 The Convention on the Conservation of Migratory Species of Wild Animals (CMS or Bonn Convention) (1983) ...... 48 5.11.4 The Agreement on the Conservation of African-Eurasian Migratory Waterbirds (AEWA) (1999) ...... 48 5.12 Policies and Guidelines ...... 48 5.12.1 Environmental Impact Assessment Guidelines ...... 48 5.12.2 Noise Standards ...... 49 5.12.3 South African Wind Energy Facility Guidelines ...... 51
6 ASSESSMENT OF ALTERNATIVES ...... 52 6.1 The No Development Scenario or “No-Go Option” ...... 52
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6.2 Site Selection ...... 53 6.3 Design Evolution Alternatives ...... 57 6.4 Technology Alternatives ...... 57
7 GEOLOGY, SOILS AND AGRICULTURAL POTENTIAL ASSESSMENT ...... 60 7.1 Methodology ...... 60 7.2 Baseline Environment...... 61 7.3 Assumptions and Limitations ...... 62 7.4 Preliminary Assessments ...... 63 7.4.1 Construction and Operation Phase Impacts ...... 63 7.4.2 Cumulative Phase Impacts ...... 64 7.5 Summary / Conclusion ...... 64
8 FLORA AND FAUNA (TERRESTRIAL ECOLOGY) ASSESSMENT ...... 65 8.1 Methodology ...... 65 8.1.1 Pattern ...... 65 8.1.2 Process ...... 65 8.2 Baseline Environment...... 66 8.2.1 Vegetation types ...... 66 8.2.2 Listed and Protected Plant Species ...... 67 8.2.3 Mammals ...... 67 8.2.4 Reptiles ...... 68 8.2.5 Amphibians ...... 68 8.2.6 Critical Biodiversity Areas and Broad Scale Processes (BSP) ...... 68 8.2.7 Site Sensitivity Assessment ...... 71 8.3 Assumptions and Limitations ...... 72 8.4 Identification of Potential Impacts ...... 73 8.5 Preliminary Assessments ...... 73 8.5.1 Construction Phase Impacts ...... 73 8.5.2 Operational Phase Impacts ...... 74 8.5.3 Cumulative Phase Impacts ...... 77 8.6 Conclusions and Recommendations ...... 77
9 AVIFAUNA ASSESSMENT ...... 79 9.1 Methodology ...... 79 9.2 Baseline Environment...... 79 9.2.1 Bird microhabitats ...... 79 9.2.2 Bird sensitivity in the area ...... 80 9.2.3 Priority species in the study area ...... 80 9.3 Assumptions and Limitations ...... 81 9.4 Preliminary Assessments ...... 81
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9.4.1 Construction Phase Impacts ...... 82 9.4.2 Operational Phase Impacts ...... 82 9.4.3 Cumulative Phase Impacts ...... 84 9.5 Summary / Conclusion ...... 84
10 BAT ASSESSMENT ...... 86 10.1 Methodology ...... 86 10.2 Baseline Environment...... 87 10.2.1 Bat micro-habitats ...... 87 10.2.2 Bat Community ...... 90 10.2.3 Sensitivity mapping for Juno WEF ...... 92 10.3 Assumptions and Limitations ...... 93 10.4 Preliminary Assessments ...... 93 10.4.1 Construction Phase Impacts ...... 93 10.4.2 Operational Phase Impacts ...... 94 10.4.3 Decommissioning Phase Impacts ...... 95 10.4.4 Cumulative Phase Impacts ...... 95 10.5 Summary / Conclusion ...... 96
11 FRESHWATER AND WETLANDS ASSESSMENT...... 98 11.1 Methodology ...... 98 11.2 Present Ecological State and conservation importance ...... 98 11.3 Baseline Environment...... 99 11.4 Assumptions and Limitations ...... 100 11.5 Preliminary Assessments ...... 100 11.5.1 Construction and Operational Phase Impacts ...... 100 11.5.2 Construction Phase Impacts ...... 100 11.5.3 Cumulative Phase Impacts ...... 101 11.6 Conclusion ...... 102
12 NOISE ASSESSMENT ...... 105 12.1 Methodology ...... 105 12.1.1 Estimation of Noise Levels ...... 105 12.1.2 Estimation of the Desired Rating Level ...... 105 12.1.3 Assessment ...... 105 12.2 Baseline Environment...... 105 12.2.1 Developments to be included in the investigation ...... 105 12.2.2 Developments to be excluded in the investigation ...... 106 12.3 Assumptions and Limitations ...... 106 12.3.1 Estimation of the expected rating level ...... 106 12.4 Preliminary Assessments ...... 107
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12.4.1 Construction Phase Impacts ...... 107 12.4.2 Operational Phase Impacts ...... 107 12.4.3 Decommissioning Phase Impacts ...... 108 12.4.4 Cumulative Phase Impacts ...... 109 12.5 Summary / Conclusion ...... 109
13 LANDSCAPE AND VISUAL ASSESSMENT ...... 110 13.1 Methodology ...... 110 13.1.1 View shed Analysis ...... 110 13.2 Baseline Environment...... 110 13.2.1 Locality ...... 110 13.2.2 Description of the Landscape Character ...... 110 13.3 Assumptions and Limitations ...... 111 13.4 Preliminary Assessments ...... 111 13.4.1 Construction / Operational and Decommissioning (All) Phases Impacts .. 111 13.4.2 Cumulative Impact Phase Impacts ...... 115 13.5 Summary / Conclusion ...... 117
14 CULTURAL HERITAGE, ARCHAEOLOGY, AND PALEONTOLOGY ASSESSMENT ...... 118 14.1 Methodology ...... 118 14.1.1 Literature Survey and Information Sources ...... 118 14.1.2 Field Survey ...... 118 14.2 Baseline Environment...... 118 14.2.1 Archaeological Aspects ...... 118 14.2.2 Historical Aspects ...... 119 14.3 Assumptions and Limitations ...... 119 14.4 Preliminary Assessments ...... 119 14.4.1 Impacts to Archaeological Resources ...... 119 14.4.2 Impacts to Palaeontological Resources ...... 120 14.4.3 Impacts to Graves ...... 121 14.4.4 Impacts to Cultural Landscapes ...... 122 14.4.5 Cumulative Phase Impacts ...... 124 14.5 Summary / Conclusion ...... 127
15 SOCIO-ECONOMIC ASSESSMENT ...... 128 15.1 Methodology ...... 128 15.2 Baseline Environment...... 128 15.2.1 Legislative and Policy Context ...... 128 15.2.2 Administrative Context ...... 129 15.2.3 West Coast Municipality ...... 129 15.3 Assumptions and Limitations ...... 131
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15.4 Preliminary Assessments ...... 131 15.4.1 Construction Phase Impacts ...... 131 15.4.2 Operational Phase Impacts ...... 134 15.4.3 Decommissioning Phase Impacts ...... 137 15.4.4 Cumulative Phase Impacts ...... 138 15.4.5 Assessment of No-Development Option ...... 139 15.5 Summary / Conclusion ...... 140
16 PUBLIC PARTICIPATION ...... 141 16.1 Key Stakeholders ...... 141 16.2 Tasks Undertaken Thus Far ...... 141 16.3 Synopsis of Key Issues ...... 141
17 SUMMARY OF FINDINGS ...... 185 17.1 Preliminary Significance Assessment ...... 185 17.2 Preliminary Environmental Sensitivity Map ...... 196 17.3 Conclusion ...... 196
18 PLAN OF STUDY FOR EIA PHASE ...... 196 18.1 Plan of Study Requirements ...... 197 18.2 Alternatives ...... 197 18.3 Aspects to be assessed by Specialists and Methodologies Employed ...... 198 18.3.1 Fauna and Flora (Terrestrial Ecology) ...... 198 18.3.2 Avifauna ...... 198 18.3.3 Bats 199 18.3.4 Freshwater and Wetlands ...... 200 18.3.5 Noise ...... 200 18.3.6 Landscape and Visual ...... 201 18.3.7 Cultural Heritage, Archaeology and Palaeontology ...... 202 18.3.8 Socio-Economics ...... 202 18.3.9 Traffic Management Plan ...... 203 18.4 Significance Assessment Methodology ...... 204 18.4.1 Extent (spatial scale) ...... 204 18.4.2 Duration ...... 204 18.4.3 Intensity (severity) ...... 205 18.4.4 Probability of Occurrence ...... 205 18.4.5 Status of the Impact ...... 205 18.4.6 Degree of Confidence in Predictions: ...... 205 18.4.7 Consequence: (Duration X Extent X Intensity) ...... 205 18.4.8 Overall Significance of Impacts ...... 206 18.5 Cumulative Impact Assessment ...... 206
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18.6 Consultation with the DEA ...... 207 18.7 EIA Phase Public Participation Process (PPP) ...... 207
APPENDIX A: EAP CV AND COMMISSIONER OF OATHS ...... 208
APPENDIX B: PUBLIC PARTICIPATION ...... 210
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1 INTRODUCTION Arcus Consultancy Services South Africa (Pty) Ltd has been appointed by AMDA Developments to conduct the Environmental Impact Assessment (EIA) process as required by the National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA), as amended, for the proposed establishment of the Juno 140 MW Wind Energy Facility (WEF) and its associated infrastructure, including its grid connection. The proposed development aims to generate and produce electricity from renewable wind energy sources in order to supply electricity into the national grid by connecting the proposed WEF and its electrical infrastructure to the existing Eskom Juno Substation. The proposed Juno WEF is located approximately 5 km north east of the coastal town of Strandfontein in the Matzikama Local Municipality within the greater West Coast District Municipality, Western Cape Province. Electricity generated by Juno WEF will be evacuated to the national grid through overhead powerlines connecting the WEF to the existing Eskom Juno substation, located approximately 16 km north east of the proposed WEF site.
1.1 Aims and Purpose of this Report The purpose of this report is to present baseline environmental and technical information on the proposed development. Information has been obtained from both specialists’ investigations and through a public participation process (PPP): This report will therefore aim to: describe the technical details of the proposed development (project description); describe and assess the need and desirability of the proposed development; describe the EIA methodology and process followed to date; present, discuss and assess alternatives; describe the baseline environment within which the proposed development would be situated; document the PPP undertaken as part of the scoping process; identify potential impacts and provide a preliminary assessment of the significance of these impacts; present initial mitigation measures for the design, construction, operation and decommissioning and closure phases of the proposed development; and identify and document issues and aspects which will require further specialist investigation and assessment in a Plan of Study for the EIA phase.
1.2 Overview of the Proposed Development The proposed 140 MW Juno WEF would consist of the following infrastructural components: Up to 59 Siemens-Gamesa turbines with a generation capacity of either 2.6 or 3.4 MW; The 2.6 MW turbine model (SG 2.6-114) has a rotor diameter of 114 m, a hub height of 80 - 93 m and blade length of 56 m; The 3.4 MW turbine model (SG 3.4-132) has a rotor diameter of 132 m, a hub height of 84 - 114 m and blade length of 64.5 m; Foundations, crane pad and hardstands associated with the wind turbines of up to 25 X 25 m; Internal access roads of between 6 - 12 m wide and a maximum of 50 km in length; Medium voltage underground electrical cables will be laid to transmit electricity generated by the wind turbines to the on-site substation; An on-site 33/132 kV substation, transformers and control building of maximum 200 X 200 m to facilitate stepping up the voltage from medium to high voltage (132 kV) to enable the connection of the WEF to the existing Eskom Juno substation; The power generated will be fed into the national grid; A 16 km 132 kV high voltage overhead power line from the on-site substation to the existing Juno substation and the national grid (to be assessed in a separate Basic Assessment application process); and 10 000 m2 laydown area and 10 000 m2 construction site camp.
The total size of the development site is 4 682 hectares. The footprint of the proposed development is estimated to be less than 10 % of this area.
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1.3 Project Proponent AMDA Developments is an international renewable energy company specialised in the development, construction and management of high-value projects in the energy and sustainability fields.
1.4 The Environmental Impact Assessment Project Team
1.4.1 Environmental Assessment Practitioners (EAPs) The co-ordination and management of this EIA process is being conducted by Arcus Consultancy Services South Africa (Pty) Ltd (‘Arcus’) with the lead EAP being Ashlin Bodasing. Refer to Appendix A for the EAP’s Declaration of Interest and Curriculum Vita.
Ashlin Bodasing
Qualifications Bachelor of Social Science (Geography and Environmental Management) Experience 11 years in Years Ashlin Bodasing is the Team Leader at Arcus Consulting, located in Cape Town. Having obtained her Bachelor of Social Science Degree from the University of Kwa-Zulu Natal; she has over 10 years’ experience in the environmental consulting industry in southern Africa. She has gained extensive experience in the field of Integrated Environmental Management, environmental impact assessments and public participation. She has also been actively involved in a number of industrial and infrastructural projects, including electricity power lines and substations; road and water infrastructure upgrades and the installation of telecommunication equipment and as well green field coal mines, as well Experience as renewable energy facilities, both wind and solar. Ashlin has major project experience in the development of Environmental Impact Assessments, Environmental Management Plans and the monitoring of construction activities. Her areas of expertise include project management, environmental scoping and impact assessments, environmental management plans, environmental compliance monitoring and environmental feasibility studies. Experience also includes International Finance Corporation Performance Standards and World Bank Environmental Guidelines environmental reviews. She has worked in Mozambique, Botswana, Lesotho and Zimbabwe. Ryan David-Andersen
Qualifications Bachelor of Science (Environmental Science and Botany) Experience 7 years in Years Ryan David-Andersen is an Environmental Sustainability Expert; a South African citizen who has travelled extensively. Ryan has cultivated diverse experience in the environmental field during his 7 years working in the industry. He has fulfilled the role of Environmental Assessment Practitioner on several EIA and BAR Projects in South Africa and Botswana including ecological specialist input. Ryan has extensive Experience construction (on-site) Environmental Control Officer experience on large developments such as wind farms, substations and mines. Knowledge of the EIA process combined with practical on-site implementation experience means that Ryan has an in-depth understanding of integrated environmental management and the principles of sustainable development. Ryan has a deep-seated love for nature that is reflected in all aspects of his work.
Arcus is a specialist environmental consultancy providing environmental services to the renewable energy market. Arcus has advised on over 150 renewable energy projects in the United Kingdom and South Africa, with environmental management and in-house specialist services.
1.4.2 Specialists The EAPs have assembled a team of technical specialists to undertake studies for the proposed Juno WEF. The specialists’ fields of investigation are listed in Table 1.1 below. The areas of investigation have been identified as relevant to the proposed development as per the experience of the EAP and consultation with the listed specialists who are familiar with the locality and nature of development. Should further topics
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be identified in the scoping process through consultation, these will be considered for inclusion in the scope of the EIA. These specialists have been selected based on their experience in the field of EIA and of renewable energy projects, and the locality of the proposed development. Table 1.1: EIA Project Team Name Organisation Role
Ashlin Bodasing Arcus Consultancy Services Project Leader (Environmental Assessment Practitioner) Ryan David-Andersen Arcus Consultancy Services Environmental Assessment Practitioner Rob Simmons Birds and Bats Unlimited Bird Impact Assessment and Pre- Construction Monitoring Craig Campbell BioInsight Bat Impact Assessment and Pre- Construction Monitoring Simon Todd Simon Todd Consulting Terrestrial Ecological Impact Assessment (Flora and Fauna) Dr Jayson Orton (with ASHA Consulting Cultural Heritage, Archaeology and John Pether - Geological Palaeontology Impact Assessment and Palaeontological Consultant) Dr Brian Colloty Scherman Colloty and Freshwater and Wetlands Impact Associates Assessment Michael Reid Arcus Consultancy Services Noise Impact Assessment Johan Claasens Zone Land Solutions Landscape and Visual Impact Assessment Garry Patterson Agricultural Research Council Geology, Soils and Agriculture Impact Assessment Tony Barbour Tony Barbour Environmental Socio-Economic Impact Assessment Consulting and Research
1.5 Assumptions and Limitations The assumption is made that the information on which this report is based (baseline studies and project information, as well as existing information) is accurate and correct. The project description information provided is preliminary and will require further detailed investigation, which will form part of the subsequent stages of this EIA. Statements or indicators of significance in this report must be considered in light of the uncertainty regarding the exact extent and significance of resources on the site at this stage of the process. The general location of the proposed wind turbines, maximum extent of access roads, and the connection of routings have been indicated. The actual position of each wind turbine will be determined by the outcome of the EIA process, as will the exact location of the proposed operations and maintenance buildings. With respect to specialist assessments, most have assumed that the issues identified are likely to be similar to other proposed WEF projects in the area, and desktop surveys and site visits have been carried out for the Scoping Phase of this EIA. Site visits, and modelling where necessary, will be undertaken in the EIA Phase.
1.6 Structure of this Report The Final Scoping Report is set out in two volumes: Volume 1: Final Scoping Report; and Volume 2: Specialists’ Studies.
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Table 1.2: Structure of this Report Section Title Containing
Introduction Introduction and background to the 1 proposed project. Project proponents and the EIA project team. Scope of work and Scoping Phase Scoping and EIA Process Methodology, Methodology including a description of specialist studies 2 and survey methodologies conducted for this study. Description of Public Participation Process methodology, and the Plan of Study for Scoping.
3 Description of the Proposed Project description, including an overview Development of the site location, the proposed WEF. Need and Desirability of the Proposed Documents the assessment of the proposal 4 Development in terms of its need and desirability, including a review of policies in support of renewable energy developments. Environmental Legislation Environmental Legislative Context and 5 Planning and National Legislation and Policy on Renewable Energy
6 Assessment of Alternatives Describes project alternatives, including the preferred option. Description of the Baseline Specialist assessments including visual, Environment and Preliminary Impact terrestrial ecology (flora and fauna), bats, Assessments wetlands and freshwater ecology, avifauna, soils and agriculture, cultural heritage, archaeology and palaeontology, noise and social. For each field, the following is 7 - 15 provided: Methodology and limitations; Baseline environment; Potential impacts; Mitigation measures; and Preliminary assessments.
16 Public Participation Summarises the PPP undertaken to date and includes the Issues Trail. Summary of Findings Summarises the findings of the specialists’ 17 assessments. Presents the preliminary Constraints Map and conclusion. Plan of Study for EIA Phase Documents aspects requiring further 18 assessment and the assessment methods proposed for the EIA Phase.
1.7 Comments on Draft Scoping Report from the Department of Environmental Affairs The table below reflects the comments received from the DEA on the DSR. This table also reflects the relevant sections in this FSR where these comment have been addressed.
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Table 1.1: DEA Comments on DSR
No. Comment from DEA EAP Response Section in Report
1 Project Description: References to the 16km 132kV Section 1.2 overhead powerline which is to be Overview of the The Department acknowledged that the assessed in a separate application Proposed information about the 16km 132kV process will be removed in the Development and power line which will be assessed in a Environmental Impact Assessment Section 3.8 The separate application is provided in the (EIA) Report. Reference to the Grid Connection application, however, you are advised overhead powerline will remain Associated with the to not include the aforesaid activity as within the Final Scoping Report WEF part of this project description as bullet (FSR). point (accepted as information sharing). Reference to this evacuation route in the Application Form Project Description will be removed and an Amended Application will be submitted to the DEA alongside the Final Scoping Report.
2 General Information [email protected] N/A Please provide an email address of the contact person for the applicant.
3 Environmental Assessment Practitioner [email protected] N/A Information: Arcus Consultancy Services Please provide a complete information South Africa (Pty) Ltd of the EAP i.e. email address and a Office 220 complete physical address. Cube Workspace Cnr Long Street and Hans Strijdom Ave Cape Town 8001
4 Activities applied for: Activity 27 of GN R983, activity 6 Section 5.1 The The Department has noted that both of GN R984 and activity 10 of GN National activity 27 of GN R983 and activity 15 R985 have been removed from the Environment of GN R984 have been applied for, application. An Amended Management Act, both pertain to the clearance of Application will be submitted to 1998 (Act 107 of indigenous vegetation. Please provide the Department with the FSR. 1998) clarity on which one is triggered by this development as both activities cannot be triggered by this development. Please provide clarity on how this project will trigger activity 6 of GN R984, considering that the criteria for the requirement of a permit or a license i.e. if the operation of a facility will result in generation or release of emissions, pollution or effluent. The Department has noted that you applied for both activity 14 of GN R 983 and activity 10 of GN R985, please ensure that you confirm the exact volume of dangerous goods to be stored in the facility as this will inform you of the applicable activity.
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No. Comment from DEA EAP Response Section in Report
5 Activity Coordinates 31°43'41.22''S 18°14'55.42''E N/A Please provide four corner coordinates 31°41'41.37''S 18°18'39.55''E of the preferred site alternative in degrees, minutes and seconds. 31°43'48.19''S 18°21'24.81''E 31°45'44.72''S 18°15'33.32''E
6 Alternatives A Pre-Feasibility assessment Section 6 Please provide a description of the undertaken by the developer is Assessment of identified alternatives for the used to identify a suitable WEF Alternatives proposed activity that are feasible site. The proposed Juno WEF was and reasonable, including the identified as a preferred site based advantages and disadvantages that on criteria that include the proposed activity or alternatives environmental constraints, land will have on the environment and on use and land availability, grid the community that may be affected connection availability, wind by the activity as per Appendix 2, (2) resource, site access and technical (1) (h) (i-xi), of GN R.982 of 2014, as feasibility for construction. amended. Section 6 of the FSR provides Alternatively, you should submit further detail on the site selection written proof of an investigation and process (Section 6.2) as well as motivation if no reasonable or other alternatives considered. feasible alternatives exist as per the Reasonable and feasible requirements of Appendix 2, (2) (1) alternatives are provided under (h) (x). Section 6 of the FSR. No alternative site for the proposed WEF was assessed during Scoping and EIA due to the site selection process detailed in Section 6.2 of the FSR.
7 Impacts Assessment ‘Table E: Legislative Requirements Pages viii - ix This Department requests the EAP to for the Content of this Final familiarise themselves with the Scoping Report’ on Page viii of the requirements of Appendix 2 of GNR 982 FSR provides reference to Sections of the EIA Regulations, 2014 (as of the FSR where each aspect of amended) and ensure that the final SR Appendix 2 of GNR 982 of the EIA submitted to this Department for Regulations 2014 (as amended) consideration meets the requirements ‘Content of Scoping Reports’ is in terms of identifying, assessing and addressed within the FSR. providing mitigation measures of the impacts on the alternatives and preferred site.
8 Specialist Report A Traffic Impact Assessment will Section 18.3.10 Please ensure that the appropriate be conducted by the Traffic Traffic specialist input to address potential Specialist during EIA. Management Plan traffic impacts of this developments is under Section 18 used. Plan of Study for EIA Phase
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No. Comment from DEA EAP Response Section in Report
9 Public Participation Process The EAP has addressed all I&AP Section 16.3 Please ensure that all issues raised comments on the Draft Scoping Synopsis of Key and comments received during the Report (DSR) received within the Issues circulation of the draft SR from the Comments and Responses Trail registered I&APs and organs of state (Table 16.1: Summary of Issues which have jurisdiction (including this Raised and Project Team Department's Biodiversity Section) in Responses) in the FSR. respect of the proposed activity are
adequately addressed in the final SR. Proof of correspondence with the Proof of all I&AP correspondence various stakeholders must be is provided in Appendix B of the included in the final SR, should you FSR. be unable to obtain comments, proof of the attempts that were made to The Public Participation Process is obtain comments must be submitted being conducted in terms of to the Department. Regulations 39, 40, 41, 42, 43 & The Public Participation Process must 44 of the EIA Regulations 2014 as be conducted in terms of Regulations amended. Cognisance is also 39, 40, 41, 42, 43 & 44 of the EIA taken of the DEA (2017) Public Regulations 2014, as amended. Participation guideline.
10 General Comments ‘Table E: Legislative Requirements Pages viii - ix You are further reminded that the final for the Content of this Final SR to be submitted to this Department Scoping Report’ on Page viii of the must comply with all the requirements FSR provides reference to Sections in terms of the scope of assessment of the FSR where each aspect of and content of Scoping reports in Appendix 2 of GNR 982 of the EIA accordance with Appendix 2 and Regulations 2014 (as amended) Regulation 21(1) of the amended EIA ‘Content of Scoping Reports’ is Regulations, 2014. addressed within the FSR. Compliance with Regulation 21(1) of the EIA Regulations 2014 as amended is provided.
11 Further note that in terms of The EAP acknowledges the N/A Regulation 45 of the EIA Regulations reference to Regulation 45 of the 2014, this application will lapse if the EIA Regulations 2014 as amended. applicant fails to meet any of the
timeframes prescribed in terms of the these Regulations, unless an extension The EAP and developer has been granted in terms of acknowledge the reference to Regulation 3(7). Section 24F of the National Environmental Management Act, You are hereby reminded of Section Act No 107 of 1998, as amended 24F of the National Environmental stating that no activity may Management Act, Act No 107 of 1998, commence prior to an as amended, that no activity may environmental authorisation being commence prior to an environmental granted by the Department. authorisation being granted by the Department.
1.8 Amendments from Draft to Final Scoping Report This Final Scoping Report (FSR) and Plan of Study for EIA, presents an update from the Draft Scoping Report (DSR) taking into account information gathered during the public consultation process. In order to assist the reader the table below reflects the sections of this document, in which changes / amendments have been made to the DSR in completion of this FSR and Plan of Study for EIA.
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Table 1.2 Amendments from DSR to FSR DSR FSR Section Title Description of Amendment Reference Reference Executive Executive Executive Summary Updated to reflect current status of the Summary Summary project including an update of the Listed Activities table. 1 1 Introduction Updated to reflect current status of the project. 1.6 1.6 Structure of this Report Updated to reflect current status of the project. n/a 1.7 Comments on Draft Inserted into FSR a Comments and Table 1.3 Scoping Report from Response Table to address comments DEA supplied by DEA. n/a 1.8 Amendments from Inserted into FSR and PSEIA to signpost Table 1.4 Draft to Final Scoping changes from DSR to FSR. Report 2.0 2.0 Scope of Work and Updated to reflect current status of EIA Scoping Phase project. Methodology 2.1 2.1 Scoping Phase Public Updated to reflect current status of EIA Participation Process project. (PPP) 2.3 2.3 Contents of the Scoping Updated to reflect current status of EIA Report project. 3.8 3.8 The Grid Connection Updated to reflect current status of EIA Associated with the project. WEF 4.2 4.2 Wind Energy Facilities Updated to address I&AP comments on Contribution to DSR. Mitigating Climate Change 5.1 5.1 The National Updated Listed Activities triggered by the Table 5.1 Table 5.1 Environment proposed Juno WEF. Management Act, 1998 (Act 107 of 1998) 6.2 6.2 Site Selection Updated to address I&AP comments on Table 6.1 DSR. 16.2 16.2 Tasks undertaken thus Updated to reflect current status of the far PPP. 16.3 16.3 Synopsis of Key Issues Updated to reflect current synopsis of Key Issues. Table 16.1 Table 16.1 Summary of Issues Table updated to reflect additional Raised and Project comments received including Project Team Team Responses responses. 17.0 17.0 Summary of Findings Updated to reflect current status of EIA project. 17.3 17.3 Conclusion Updated to reflect current status of EIA project. 18 18 Plan of Study for EIA Updated to reflect the comments that will Phase be addressed by specialists in the EIA phase.
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DSR FSR Section Title Description of Amendment Reference Reference Appendix B5 Appendix B5 I and AP Database Updated with additional I&AP registrations. Appendix B6 Appendix B6 Comments and Updated with additional comments by Responses Trail I&APs and responses by the Project Team. Appendix B7 Appendix B7 Correspondence Updated with additional correspondence. n/a Appendix B8 Notification of Updated to include evidence of Notification Availability of the DSR of Availability of DSR for Public Review for Public Review n/a Appendix B9 Proof of Delivery of Updated to include Proof of Delivery of DSR DSR. n/a Appendix Public Meeting – Updated to include evidence of Public B10 Scoping Phase Meeting held.
2 SCOPE OF WORK AND SCOPING PHASE METHODOLODY The EIA process formally commences with notifying the competent authority (in this case the Department of Environmental Affairs (DEA)) of the proposed development through the submission of an application form. The EAP, along with a team of technical specialists, commence the Scoping Phase, in order to inform decision regarding the appropriate “scope” of the EIA phase. The existing environmental baseline of the site proposed for development is established during this phase through a desktop assessment and site visits. The type of development is considered and its anticipated impacts on the existing environment informs the specialists’ studies to be undertaken. The methodology of how these impacts should be assessed within the EIA phase is also determined. A Draft Scoping Report (DSR) was compiled which was made available for public review for a legislated period of 30 days. All comments received in response to the DSR were considered, responded to in the Comments and Responses Trail and incorporated into this Final Scoping Report (FSR) and Plan of Study for Environmental Impact Assessment. This FSR is submitted to the DEA, as the competent authority, for approval. Interested and Affected Parties (I&APs) are provided with the opportunity to comment on the FSR and submit their comments directly to the DEA. Should the FSR be approved by the DEA, the EIA Phase is initiated, which includes further detailed specialist assessments. A Draft EIA Report is compiled and incorporates these findings. The Draft EIA Report is made available for stakeholder review for a period of 30 days. Comments are again considered and responded to in a Final EIA Report. I&APs are then notified of the submission of the Final EIA Report to DEA and any comments on the final report can be submitted directly to the DEA. Once a Final EIA Report has been submitted, the competent authority (the DEA) will make a decision within 107 days on whether to grant or refuse Environmental Authorisation for the application. Based on environmental requirements and the experience of the developer and project team, the following issues are to be assessed for the proposed Juno WEF EIA process: Fauna and Flora (Terrestrial Ecology); Avifauna (Birds); Bats; Freshwater and Wetland Ecology; Noise; Landscape and Visual; Soils and Agriculture; Archaeology, Palaeontology and Cultural Heritage; Access, Traffic and Transportation; and Socio-economics including tourism. The Scoping Phase of the EIA process refers to the process of determining spatial and temporal boundaries for the study, along with determining those potential impacts that should be assessed in further detail during the EIA Phase. In broad terms, this involves three activities:
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Agreement of process to be followed including stakeholder engagement opportunities; Clarification of the scope of the project that is to be assessed; and Identification of key issues/impacts to be addressed during the EIA Phase and the methodology that is to be followed in order to address those issues. The above activities are completed through consultation with: The lead authorities involved in the decision-making for the EIA application (in this case, the DEA); The public, I&APs and other relevant organisations to ensure that local issues are well understood; and The EIA specialist team to ensure that all technical issues are identified. The existing environment within which a proposed development is to be located is investigated, through a review of relevant background literature, as well as a site visit where necessary. A primary objective during this phase is to present key stakeholders with an overview of the elements of the proposal that will require further assessment in the EIA Phase.
2.1 Scoping Phase Public Participation Process (PPP) Public participation is an essential component of the EIA process. The process of public involvement encourages I&APs to contribute their comments and concerns regarding the proposed development during the entire EIA process. In general, the PPP ensures that: The general public is notified of the proposed project and afforded the opportunity to register as I&APs; Key I&APs are identified as directed by legislation and informed about the proposed development and its implications; All issues, underlying concerns and suggestions raised by I&APs are understood, documented and addressed; and Areas that require further specialist investigation are identified and feedback is provided to I&APs.
The PPP for this Scoping and EIA process takes cognisance of the DEA (2017) Public Participation Guideline in terms of NEMA EIA Regulations.
Throughout the process, stakeholders will be encouraged to communicate with the PPP team to raise issues, ask questions or make suggestions. Communication will be through telephonic means or in written form. All issues will be included into the Comments and Responses Trail, and responded to and addressed by the project team. Registration of I&APs will continue throughout the Scoping & EIA process. Comments on the draft reports will need to be received within the specified time periods to ensure they can be taken into account within the final documents, and submitted to the DEA within the legislated timeframes. The sections below describe the tasks that were undertaken as part of the public engagement process during the Scoping Phase.
2.1.1 Pre-Scoping Advertisements were placed in the relevant local and provincial newspapers (in English and Afrikaans); Site notices were erected on the site boundary; Written notices to the affected land owners and occupiers of the site, municipal councillor(s), ratepayers in the area, affected district and local municipalities, and organs of state were delivered; and Relevant stakeholders, I&APs and organs of state were identified and a project database was compiled.
Proof of the above can be found in Appendix B.
2.1.2 Scoping Phase Notification letters were sent out to registered I&APs, key stakeholders, and organs of state to inform them of the availability of the Draft Scoping Report (30 day review period ending 09th July 2018); A Comments and Responses Trail Report was compiled, recording comments and/or queries received and recording the responses provided; and
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A Public Meeting was held at Strandfontein Municipal Hall on the 03rd July 2018 from 17:00 to 18:40 in order to explain the findings of the Scoping Report, and present to the public what issues shall be investigated during the EIA Phase. Minutes of this meeting are available in Appendix B8. 2.2 Specialist Scoping Assessments Each technical/specialist assessment follows a systematic approach, with the principal steps being: Description of baseline conditions; Prediction of potential impacts including cumulative impacts; Assessment of potential impacts; Identification of appropriate mitigation measures; and Assessment of potential residual environmental impacts.
Each technical/specialist chapter is broadly structured as follows: Introduction; Assessment methodology and significance criteria; Baseline conditions; Development design mitigation; Assessment of potential effects; Mitigation measures and residual effects; Cumulative effects assessment; Summary of potential effects; and Statement of significance. 2.2.1 Baseline Description In order to evaluate the potential environmental impacts, information relating to the existing environmental conditions or baseline environment is collected through field and desktop research. The baseline environment also extends into the future, although predictions of any changes can involve a high number of variables and be subject to potentially large uncertainties. As a result, in most cases, the baseline is assumed to remain unchanged throughout the operation of the development. Where this is not the case, this is stated. The baseline environment has been used to identify any potential sensitive receptors on and near the site, and it is used to assess what changes may take place during the construction, operation and decommissioning phases of the development and the effects, if any, that these changes may have on these receptors. Within each technical assessment, the methods of data collection are discussed with the relevant specialists. Data is also collected from public records and other archive sources and where appropriate, extensive field surveys are carried out. The timing/seasonality of the work within the study area is also outlined within each assessment.
2.2.2 Prediction of Potential Impacts The prediction of potential impacts covers the phases of construction, operation and decommissioning. During each phase of the development, different environmental effects are likely to arise. For example, during the construction phase, traffic volumes are far greater than during the operational life of a WEF. Each specialist assessment covers: Direct and indirect effects; Short, medium and long term effects; Permanent and temporary effects; Likelihood of an effect occurring (i.e. very likely, likely, or unlikely); and Cumulative effects.
Following the identification of potential environmental impacts, the baseline information is used to predict changes to existing conditions, and undertake an assessment of these changes.
2.2.3 Assessment of Potential Impacts The potential impact that the proposed development may have on each environmental receptor is influenced by a combination of the sensitivity or importance of the receptor and the predicted degree of alteration from the baseline state (either beneficial or adverse).
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Environmental sensitivity (or importance) may be categorised by a multitude of factors, such as threat to rare or endangered species, transformation of natural landscapes, or changes to soil quality and land use. The initial assessment, consultation and scoping phases identify these factors along with the implications of the predicted changes. Unless stated otherwise in each specialist chapter, the sensitivity or importance of each identified receptor is defined as high, medium, low or negligible. Likewise, the degree of alteration from the baseline state is defined as high, medium, low or negligible. The overall significance of a potential environmental impact is determined by the interaction of the above two factors (i.e. sensitivity/importance and predicted degree of alteration from the baseline). In order to evaluate the potential environmental impact each specialist has used the same methodology to evaluate and assess impacts in their reports in line with the definitions described above, unless otherwise stated (e.g. the definition of what constitutes a receptor of ‘high’ sensitivity).
2.2.4 Mitigation Specialists shall also propose measures to avoid, reduce or remedy potential significant adverse impacts. These are mitigation measures. Where the assessment process has identified any significant adverse impacts, mitigation measures are proposed to reduce these impacts. Such measures include the consideration of alternatives, physical design evolution, such as movement or loss of turbines, and management and operational measures. This strategy of avoidance, reduction and remediation is a hierarchical one which seeks: First to avoid potential effects; Then to reduce those which remain; and Lastly, where no other measures are possible, to propose compensatory measures. Each specialist consultant identifies appropriate mitigation measures (where relevant). These measures will largely be embedded into the overall design strategy rather than “added on”. By being flexible with design, the EIA team and the applicant/developer will be able to respond to the findings of consultation and EIA work, and mitigate accordingly, as the project progresses.
2.2.5 Residual Impacts The assessment process concludes with an examination of residual effects after mitigation has been applied, i.e. the overall predicted (potential) impacts of the development.
2.2.6 Cumulative Impact Assessment In accordance with the EIA Regulations, consideration is also given to 'cumulative impacts'. For the purpose of this assessment cumulative impacts is defined and will be assessed in the future baseline scenario, i.e. Cumulative impact of the proposed development = change caused by proposed development when added to the cumulative baseline. The cumulative baseline includes all other identified developments. In the cumulative assessment the effect of adding the proposed development to the cumulative baseline is assessed. In line with best practice, the scope of this assessment will include all operational, approved or current and planned renewable energy applications (including those sites under appeal), within a 35 km radius of the site. Therefore, all potential projects are included, even though it is unknown how many of these will actually be constructed. Renewable energy sites included for cumulative impact assessment are based on the knowledge and status of the surrounding areas at the time of finalising the FSR and include seven wind energy facilities and three solar PV applications. Of the ten renewable energy facilities located within 35km of the Juno WEF only one of the WEFs is operational (Eskom Sere WEF). A preliminary assessment of cumulative impacts has been made in the Scoping Phase and will be assessed further in the EIA Phase as detailed in the Plan of Study for EIA (Section 18).
2.3 Contents of the Scoping Report The initial results from the Scoping Phase public participation and specialist investigations are collated into a concise Scoping Report. The Scoping Report contains the following information: Nature of the activity; Description of the receiving environment; Identification of potential feasible alternatives; Identification of potential positive and negative impacts; Identification of knowledge gaps; and
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A Plan of Study for the EIA phase.
Legislative requirements for the content of a Final Scoping Report are presented in Table E at the beginning of this report. The Scoping Report must contain a Plan of Study for the EIA Phase. This plan (Section 18) sets out the proposed approach to the EIA Phase study including the: tasks that will be undertaken, including specialist reports and the manner in which such tasks will be completed; stages at which the competent authority will be consulted; and description of the methods of assessment and the details of the public participation process. Once the DEA has reviewed the FSR and Plan of Study for EIA and should the DEA accept it, the EIA Phase may commence. Should the DEA reject the application, the applicant would need to re-initiate the process.
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3 DESCRIPTION OF THE PROPOSED DEVELOPMENT The proposed development will consist of up to 59 three-bladed horizontal-axis wind turbines with a maximum hub height of 114 m and blade length of 64.5 m. The maximum generating capacity of the development will be 140 MW. The final choice of turbine will be dependent on the technology available at the time of construction as well as technical and economic feasibility of the turbine models available. Currently Siemens-Gamesa turbine models SG 2.6-114 and SG 3.4-132 are being considered. The blades will be manufactured from fibre-reinforced with epoxy or polyester resin or equivalent performance materials and the towers will be of tapering or cylindrical tubular steel or steel/concrete construction. The nacelle, which is located at the top of the tower, houses the gearbox and generator. The turbines are computer-controlled to ensure that each turbine faces directly into the wind during operation to ensure optimum efficiency. When not in operation the turbine may turn away from the wind if the wind is too strong to protect the drive train. An overhead 132 kV power line will be constructed over a distance of approximately 16 km to connect the WEF to the existing Eskom Juno substation to the northeast of the site (Figure 3.1). This overhead powerline will form part of a separate application for authorisation, through a basic assessment process. The purpose of a wind energy facility is to harness energy from the wind. It is important that wind turbines are sited in the optimum position to maximise the wind yield whilst minimising environmental impacts. The optimum layout of a wind energy facility depends on a range of criteria. These vary depending on the type and size of turbine as well as the local topography and the turbulence which may be created by surface features. Turbine manufacturers generally recommend that turbines should be spaced between three and six rotor diameters apart depending on the prevailing wind direction, turbine type and site characteristics.
3.1 How Does Wind Energy Generation Work Wind turbines are used to harness kinetic energy and convert this into a useable form, electricity. WEFs consume no fuel during operation and have no direct emissions as a result of electricity production. The economies of a WEF depend upon the wind resource available at a site and as such detailed information on speed, flow, direction and regularity of wind are vital when identifying locations and layouts for WEFs. Wind turbines are mounted on a tower to elevate the generators above the ground where wind speeds are higher and the wind resource is more consistent and less turbulent. The kinetic energy of the wind is then used to turn the turbine blades, three of which are joined together to form a rotor. This movement produces mechanical power which is transmitted to the generator within a nacelle (on the top of the tower) either via a gearbox or through a direct drive design of turbine. A typical wind turbine consists of four primary components: The foundation unit upon which the turbine is anchored to the ground; The tower which will have a hub height of up to 114 m. The tower is a hollow structure allowing access to the nacelle. The height of the tower is a key factor in determining the amount of electricity a turbine can generate. The tower houses the transformer which converts the electricity to the correct voltage for transmission into the grid; The nacelle (generator/turbine housing). The nacelle houses the gearbox and generator as well as a wind sensor to identify wind direction. The nacelle turns automatically ensuring the blades always face into the wind to maximise the amount of electricity generated; and The rotor which is comprised of three rotor blades with a diameter of up to 132 m. The rotor blades use the latest advances in aeronautical engineering materials science to maximise efficiency. The greater the number of turns of the rotor the more electricity is produced.
3.2 Site Description and Location of the Proposed Development The proposed Juno WEF would be situated approximately five kilometres north east of the town of Strandfontein, Western Cape (Figure 1.1). The proposed facility would be built on the Remaining Extent of Farm De Boom No. 273. Details of the land parcel that makes up the development site are presented in Figure 3.1.
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Table 3.1: Property Details of the Proposed Development Site Size Property Owner Farm Portion SG number (ha)
Remainder of De Mariëtte Wiese C07800000000027300000 4682 Boom 273
The main access route to the site is via the R362 near Strandfontein, to the west of the site. There is a gravel road leading from the R362 that provides access to the single farm that comprises the development site. The proposed site is located on a flat to gently undulating coastal plain characterised by low shrubland vegetation. The grid connection alternatives run in a north-easterly direction from the proposed development site, crossing the Olifants River shortly before meeting the existing Eskom Juno substation. The grid connection alternatives will be assessed as a separate Basic Assessment (BA) process.
3.3 Wind Energy Facility (WEF) Components The WEF will comprise components described below. It should be noted that as the design of the proposed development is not yet finalised, all dimensions are maximums as is required by the EIA process. The final design may include infrastructure which is of equal or less than dimensions to those stated below, but not more than.
3.3.1 Turbines The proposed WEF will comprise of up to 59 turbines. At this stage, it is envisaged that the turbines will each have a capacity to generate up to 3.4 MW of power. Each turbine will have a maximum height to blade tip of 180 m. The turbines will be three-bladed horizontal-axis design with a hub height of up to 114 m and a rotor diameter of up to 132 m and a blade length of up to 64.5 m. The exact turbine model has not yet been selected and will be identified based on the wind resource distribution, technical, commercial and site specific considerations. The turbine rotor speed will vary according to the energy available in the wind, the wind speed. The turbines will generate power in wind speeds between approximately 3 metres per second (m/s) and 28 m/s (depending on the model of turbine) with maximum power output usually achieved at wind speeds of around 10 - 12 m/s. On average, wind speeds greater than approximately 25 m/s the turbines will automatically turn the angle of the blade to reduce energy capture (this is known as ‘feathering’) and stop turning to prevent damage. Each turbine will require a transformer that will be located within the turbine tower. The turbines would be placed on steel and concrete foundations, each foundation area occupying an area of up to 25 m by 25 m in total (which includes the maximum total area that may need to be disturbed during construction of the foundation). The foundation areas are typically up to 5 m deep and will include concrete and steel plinths depending upon local ground conditions. The precise location of the turbines within the WEF site has not yet been finalised and will be confirmed during the EIA process, following the assessment of technical and environmental constraints.
3.3.2 Turbine Power Output and Transformers When operating, the rotational speed of the rotor is multiplied through the gearbox, which drives the generator. This produces a three-phase power output which is transferred from the generator to a transformer located within the turbine. The turbine transformer converts the electrical output from the turbine to a higher voltage, 33 kilovolt (kV), for internal reticulation purposes. Stepping up the voltage helps to reduce electrical losses and reduce the cost of reticulation within the site. Power generated from the turbines is transmitted back to the on-site substation via the underground site cables.
3.3.3 Electric Cabling and On-site Substation The electricity from the turbines will be transferred via a 33 kV electrical cable network to two 80 MVA 33/132kV transformers located in the on-site substation. Where possible the cabling will be underground but the feasibility of this will be confirmed as the design progresses and geotechnical studies are conducted. The on-site substation will house electrical infrastructure such as transformers and switchgear
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to enable the energy to be transferred into the existing national grid. The operations and maintenance building including parking will be approximately 1 ha. Underground cabling will link the turbines to each other and to the on-site transformer/ control building. Detailed construction and trenching specifications will depend on the ground conditions encountered. Typically cables would be laid in a trench approximately 1 m deep and 0.5 m wide. To minimise ground disturbance, cables will be routed along the side of the access tracks where practicable.
3.3.4 Hard Stand Areas Each turbine requires an area of hard-standing to be built adjacent to the turbine foundation. This provides a flat, stable base on which to lay down the turbine components ready for assembly and erection and to site the two cranes necessary to lift the tower sections, nacelle and rotor into place. A hard-standing area of up to 7500 m2 will be established adjacent to each turbine location. This will be used to provide a platform for cranes to operate during construction (and unscheduled maintenance), as well as a clear area to lay out turbine components prior to erection. The crane hard-standing will be left in place following construction in order to allow for use of similar plant should major components need replacing during the operational phase of the proposed development.
3.3.5 Laydown Areas Additional temporary laydown areas will be required for equipment and component storage during construction across the site. These areas will be levelled and compacted and used for component storage. Temporary infrastructure would include a site camp, laydown areas and a batching plant.
3.3.6 Access The turbine locations will be accessed through a network of unsealed roads which will be established across the WEF Site. These access roads will be between 6 m and 12 m wide. A width of 12 m is required for curves in order to allow trucks transporting turbine components to turn. Such roads are required to facilitate access for the cranes and abnormal load deliveries of turbine components. Existing farm access roads will be upgraded and utilised where possible. Some of the aggregate required for the construction of the on-site tracks may be sourced from cut and fill operations during construction from within the proposed development site with additional material imported from permitted quarries as required. The need for this will be assessed during the EIA process. If required, a separate application will be lodged with the Department of Mineral Resources in regard to this activity.
3.3.7 Ancillary Equipment In addition to the key components outlined above, the WEF will also require: Meteorological masts; Security fencing; and CCTV monitoring equipment.
3.4 Transportation of Equipment to Site Wind turbine components can be transported in a number of ways with different truck / trailer combinations and configurations. These issues will be investigated at a later stage when the transporting contractor and the plant hire companies apply for the necessary permits from the relevant authorities. The heaviest component of a wind turbine is the nacelle (approximately 67 to 85 tons depending on manufacturer and design of the unit). Combined with road-based transport, it has a total vehicle mass of approximately 130 000 kg (for the 85 ton unit). Thus route clearances and permits will be required for transporting the nacelle by road based transport. Blades are the longest component, ranging between 56 – 64.5 m, and need to be transported on a specially imported extendible blade transport trailer or in a rigid container with rear steerable dollies. The blades can be transported individually, in pairs or in three’s although different manufacturers have different methods of packaging and transporting the blades. Where required, existing public roads may need to be upgraded along the proposed equipment transport route to allow for the transportation and delivery of wind turbine components and other associated infrastructure components.
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The national roads on the potential national access routes are generally of high standard and many of the structures have been assessed for load bearing capacity and height clearance in the past. Turbine supplier/s or the contractor selected for implementation would be responsible for the transportation of wind turbine components to site. A complete transportation management plan will be undertaken during the EIA Phase.
3.5 Description of the Construction Phase of the WEF It is estimated that construction will take approximately 12 - 24 months subject to the final design of the WEF, weather and ground conditions, including time for testing and commissioning. The construction process will consist of the following principal activities: Site survey and preparation; Site establishment (construction of Contractor laydown area); Construction of site entrance, access roads and passing places; Construction of crane pads; Construction of turbine foundations; Construction of internal substation; Excavation of the cable trenches and cable laying; Delivery and erection of wind turbines; Erection of electricity overhead powerlines; Testing and commissioning of the wind turbines; and Rehabilitation.
It is possible for certain operations to be carried out concurrently, although predominantly in the order mentioned above. This would minimise the overall length of the construction programme. Construction would be phased such that the civil engineering works would be continuing on some parts of the site, whilst wind turbines are being erected elsewhere. Site rehabilitation will be programmed and carried out in order to allow the rehabilitation of disturbed areas as early as possible and in a progressive manner.
Based on the developers’ experience from other WEF developments, the construction phase is likely to create approximately 200 employment opportunities, at its peak. Of this total, approximately 25% will be available to skilled personnel (engineers, technicians, management and supervisory), 15% to semi-skilled personnel (drivers, equipment operators) and 60% to low skilled personnel (construction labourers, security staff). The number and nature of employment opportunities will be refined as the development process progresses. These figures are based on other WEF developments, the exact number and nature of the employment opportunities will be defined during the bidding process, should the project be selected as a preferred bidder. These are requirements of the bidding process as defined by the DoE. Water for construction purposes (e.g. mass earthworks and roads) will be transferred from the source to the point of use on the site via tanker. All storage of water will be below Water Use License Application (WULA) authorisation limits, i.e. 10 000 m3. If storage has the potential to exceed this limit, a WULA will be submitted to the Department of Water and Sanitation.
3.6 Description of the Operation Phase of the WEF The proposed development will be designed to have an operational life of 20 years as set out in the current REIPPPP by the DoE. There is the possibility to further expand the lifetime by an extra 20 years. The only development related activities on-site will be routine servicing and unscheduled maintenance, as detailed in the sections below. Based on the developer’s experience from other WEFs, the operational phase is likely to create approximately 30 permanent employment opportunities. Of this total, approximately 80% will be low and medium-skilled and 20% will be high skilled positions. The number and nature of employment opportunities will be refined as the development process progresses. The figures provided here are early estimates.
3.6.1 Routine Servicing Wind turbine operations will be overseen by suitably qualified local contractors who will visit the site regularly to carry out maintenance. The following maintenance will be carried out along with any other maintenance required by the manufacturer's specifications: Initial service; Routine maintenance and servicing; Test of SCADA systems and gearboxes;
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Gearbox oil changes; Inspections of towers, nacelles and blades; and Electrical maintenance of new substation. Routine scheduled servicing will likely take place every three months with a main service likely to occur at twelve-monthly intervals. Servicing will include the performance of tasks such as maintaining bolts to the required torque, adjustment of blades, inspection of blade tip brakes and inspection of welds in the tower. In addition, oil sampling and testing from the main gearbox will be required once every year and oil and other consumables replaced at regular intervals. Technicians are on site daily to ensure that the turbines are operating safely and at their maximum efficiency. Site tracks will be maintained in good order. Safe access will be maintained all year round. The turbines are monitored 24 hours a day real-time via a supervisory control and data acquisition (SCADA) system.
3.6.2 Unscheduled Maintenance Unscheduled maintenance associated with unforeseen events will be dealt with on an individual basis. In the unlikely event of a main component failure cranes may be mobilised to site to carry out repairs and/or replacement works.
3.7 Description of the Decommissioning Phase of the WEF At the end of the operation phase, the proposed development will be decommissioned, or may be repowered i.e. redesigned and refitted so as to operate for a longer period. Repowering would not be undertaken under this application or resulting Environmental Authorization, and would be subject to a new application at the time. In the event of decommissioning, typically, all above ground equipment will be dismantled and removed from the site. Cables and the turbine foundations will be cut off below ground level and covered with topsoil. Access tracks will be left for use by the landowners, or if appropriate, covered with topsoil or reduced in width. This approach is considered to be best practice environmentally and less damaging than seeking to remove all foundations and underground cables in their entirety. Decommissioning will take account of the environmental legislation and technology available at the time of decommissioning.
3.8 The Grid Connection Associated with the WEF The electricity generated from the WEF will be transferred from the on-site switching station to the existing Eskom 132/400 kV Juno substation via 132 kV overhead power lines (Figure 3.1). From the Juno substation the energy will be transferred to the existing high-voltage lines of the national grid. The type of structures which will support the overhead lines is yet to be determined and may include: Concrete, steel or wood monopoles; Guy line supported steel structures; Free standing metal lattice towers; or Multi-pole structures such as H-towers or K-towers. The exact route of the power lines and grid connection has not yet been determined and will be informed by the basic assessment process and assessment of technical and environmental constraints. Three alternative alignments have been considered. The length of the transmission line will be approximately 16 km. The route for the 132 kV power lines will include a servitude of approximately 31 m. At this stage it is recommended that the proposed route of the overhead line follows existing linear infrastructure as far as possible as this will potentially reduce the impacts associated with its construction and operation. The exact route will be determined during the basic assessment process. Given the uncertainties at this stage of the EIA process, the scope of the grid connection will be defined further with Eskom as the project progresses. The grid connection will undergo a separate basic assessment application process and is not assessed as part of this application, reference is made for information purposes
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4 NEED AND DESIRABILITY OF THE PROPOSED DEVELOPMENT WEFs can play a role in mitigating or reducing climate change, addressing South Africa’s energy resource constraints and producing low-cost energy. In addition, operating WEFs in South Africa contribute significantly to the economic development of the areas in which they are located through the requirements of the REIPPPP adjudication process. This section of the report highlights the national, provincial and local plans and policies that are in support of renewable energy facilities. Throughout this section, it is demonstrated that at all levels of governance, policy supports the development of renewable energy in order to address energy supply issues, and to promote economic growth in South Africa. Reference is made to the Department of Environmental Affairs (DEA) 2017 Guideline on Need and Desirability5 which states that while the “concept of need and desirability relates to the type of development being proposed, essentially, the concept of need and desirability can be explained in terms of the general meaning of its two components in which need refers to time and desirability to place – i.e. is this the right time and is it the right place for locating the type of land-use/activity being proposed? Need and desirability can be equated to wise use of land – i.e. the question of what is the most sustainable use of land.” It should be noted that even though this development is located in the Western Cape, the relevance of this Guideline is still applicable, as it deals with Need and Desirability and its assessment in the EIA process. The need and desirability assessment answers the question of whether the activity or development is being proposed at the right time in the right place. The guidelines pose questions that should be considered in this investigation, which are addressed in Table 4.1 and Table 4.2 below. Table 4.1 - Ecological Considerations of Need and Desirability for Juno WEF
“securing ecological sustainable development and use of natural resources”6 Question Answer Reference • An independent Ecological Specialist forms part of the EIA project team. The Ecological Terrestrial How will this development (and its separate Specialist’s approach and methodology applied complies with NEMA: EIA Regulations 2014 Ecology elements/aspects) impact on the ecological integrity of the as amended as well as best practise guidelines and principles for biodiversity assessment Scoping area? as outlined by Brownlie (2005) and De Villiers et al. (2005). Report • The National List of Threatened Ecosystems (2011) was used to identify and map listed Terrestrial ecosystems in need of protection. Ecology Threatened Ecosystems • No threatened ecosystem falls within the site boundary. Therefore this will not be Scoping assessed further in the EIA phase. Report Sensitive, vulnerable, highly How were the following dynamic or stressed ecological integrity ecosystems, such as coastal considerations taken into • The southern section of the proposed site contains a palaeo-channel with rocky Terrestrial shores, estuaries, wetlands, account? outcrops along the channel. This locally unique and diverse habitat is considered Ecology and similar systems require sensitive and has been identified as a ‘no-go’ area for development. Scoping specific attention in • Further study on this sensitive habitat will be undertaken during EIA phase. Report management and planning procedures, especially where they are subject to
5DEA (2017) Guideline on Need and Desirability. Department of Environmental Affairs (DEA), Pretoria, South Africa, ISBN: 978-0-9802694-4-4. 6Section 24 of The Constitution of South Africa refers.
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“securing ecological sustainable development and use of natural resources”6 Question Answer Reference significant human resource usage and development pressure • Critical Biodiversity Areas (CBAs) and Ecological Support Areas (ESAs) in the study area were obtained from the 2017 Western Cape Biodiversity Spatial Plan. The development avoids a CBA 1 located in the far east of the proposed site. Terrestrial Critical Biodiversity Areas • Much of the proposed WEF will be located within an ESA 1. While some habitat loss Ecology (“CBAs”) and Ecological within the ESA will occur, no significant negative impacts are expected to extend into the Scoping Support Areas (“ESAs”) neighbouring CBA and no significant disruptions in ecological processes are likely to Report occur. • This aspect will be addressed further in the EIA phase. • Approximately 70% of the site occurs within the 2010 NPAES Knersvlakte Hantam Focus Area. • Updated finescale conservation planning has shown that the status of the proposed site should potentially be changed. Thus the NPAES 2010 is not considered as the best tool Terrestrial for conservation target planning for the WEF site. Ecology Conservation targets • The Western Cape 2016 BSP may be seen as the most accurate conservation planning Scoping tool available. Use of this conservation status tool places the majority of the Juno WEF Report footprint within an ESA. • Further information on the conservation target status of the proposed site will be provided as part of the EIA phase. • The key ecological drivers of ecosystems on the site and in the vicinity were assessed by the Ecological Specialist. Terrestrial Ecological drivers of the • The specialist concludes that the potential for disruption of ecological processes and Ecology ecosystem their drivers is low, particularly when compared to the major impact in the area - Scoping transformation for agriculture. Report • This will be assessed further in EIA phase. • No area-specific Environmental Management Framework exists for the site. • The West Coast District Municipality and Matzikama Local Municipality SDFs and IDPs provide environmental management goals and strategies. Social Environmental Management • Compliance of the project within the specific context of these policies is assessed within Scoping Framework this Social Scoping Report. Report • The proposed Juno WEF complies with all policies and planning tools. • Further detail will be provided in the EIA phase. • The West Coast District Municipality and Matzikama Local Municipality SDFs that are Social Spatial Development applicable to the project site were assessed. Scoping Framework • The proposed WEF fits into the planning context of both applicable SDFs. Report • Further detail will be provided in the EIA phase.
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“securing ecological sustainable development and use of natural resources”6 Question Answer Reference • All global responsibilities to which South Africa is signatory or party to were assessed within this report. Applicable international treaties and conventions are: • UNFCCC Paris Agreement (2016) Global and international • The Convention on Biological Diversity (CBD) (1993) responsibilities relating to Social • The Convention on the Conservation of Migratory Species of Wild Animals (CMS or Bonn the environment (e.g. Scoping Convention) (1983) RAMSAR sites, Climate Report • The Agreement on the Conservation of African-Eurasian Migratory Waterbirds (AEWA) Change, etc.) (1999) • Planning fit was assessed in the Social Scoping Report and will be further assessed in the EIA phase. • Mitigation measures to reduce residual risk or enhance opportunities (Construction): • No development of turbines, roads of other infrastructure within high sensitivity and no- go areas. • Preconstruction walk-through of the development footprint to further refine the layout and reduce impacts on SCC through micro-siting of the turbines and access roads. • Avoidance of identified areas of high fauna importance at the design stage. • Search and rescue for reptiles and other vulnerable species during construction, before areas are cleared. • Limiting access to the site and ensuring that construction staff and machinery remain within the demarcated construction areas during the construction phase. How will this development disturb or enhance ecosystems • Environmental induction for all staff and contractors on-site. and/or result in the loss or protection of biological diversity? • Mitigation measures to reduce residual risk or enhance opportunities (Operation): Terrestrial What measures were explored to firstly avoid these negative • Avoiding areas of high wind erosion vulnerability as much as possible. Ecology impacts, and where these negative impacts could not be • Using net barriers, active rehabilitation and other measures during and after Scoping avoided altogether, what measures were explored to construction to minimise sand movement at the site. Report minimise and remedy (including offsetting) the impacts? • Set up a long-term environmental monitoring plan for the site to ensure that erosion is What measures were explored to enhance positive impacts? controlled in the long-term. • Alien management plan to be implemented during the operational phase of the development, which makes provision for regular alien clearing and monitoring. • Rehabilitation of disturbed areas that are not regularly used after construction. • Minimise the development footprint as far as possible, which includes locating temporary-use areas such as construction camps and lay-down areas in previously disturbed areas. • Avoid impact to restricted and specialised habitats such as pans, wetlands and dune fields. • Further mitigation and enhancement measures to be considered as part of the EIA phase. How will this development pollute and/or degrade the • Waste streams are expected to be highest during construction of the WEF. Terrestrial biophysical environment? What measures were explored to • This aspect will be assessed further during EIA phase. The construction phase EMPr Ecology
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“securing ecological sustainable development and use of natural resources”6 Question Answer Reference firstly avoid these impacts, and where impacts could not be will provide measures for avoidance and minimisation, as well as enhancing any potential Scoping avoided altogether, what measures were explored to positive impacts. Report minimise and remedy (including offsetting) the impacts? What measures were explored to enhance positive impacts? This aspect will be assessed What waste will be generated by this development? What further measures were explored to firstly avoid waste, and where • Registered service providers will be utilised by the Contractor during construction of the during EIA waste could not be avoided altogether, what measures were WEF, when waste streams will be highest. phase and explored to minimise, reuse and/or recycle the waste? What • This aspect will be assessed further during EIA phase and measures to reduce, reuse measures to measures have been explored to safely treat and/or dispose and recycle will be included in the EMPr. reduce, of unavoidable waste? reuse and recycle will be included in the EMPr. • A Heritage Scoping Report was undertaken by an independent Heritage Specialist. Recommendations from the Heritage Scoping Report are provided below: • The Sandlaagte River Valley should be avoided in totality with no infrastructure placed within 500 m of the centre of the valley; How will this development disturb or enhance landscapes • Any as yet un-surveyed sections of the final layout should be evaluated in the field by Heritage and/or sites that constitute the nation’s cultural heritage? an archaeologist prior to construction; Scoping What measures were explored to firstly avoid these impacts, • Measures to reduce the visual impacts to the landscape should be implemented; and Report and and where impacts could not be avoided altogether, what • If any archaeological material, fossils or human burials are uncovered during the course Visual measures were explored to minimise and remedy (including of development then work in the immediate area should be halted. The find would need Scoping offsetting) the impacts? What measures were explored to to be reported to the heritage authorities and may require inspection by an archaeologist. Report enhance positive impacts? Such heritage is the property of the state and may require excavation and curation in an approved institution. • Additional recommendations for mitigation of negative impacts and enhancement of positive impacts will be provided during the EIA phase, including incorporation of Visual Specialist input to the Heritage Impact Assessment. How will this development use and/or impact on non- • Wind is considered a renewable resource and will be the ‘fuel’ for the WEF to generate renewable natural resources? What measures were explored electricity. to ensure responsible and equitable use of the resources? Terrestrial • Some non-renewable resources will be consumed during the construction phase. These How have the consequences of the depletion of the non- Ecology include hydrocarbons to be used as fuel, and soil to be removed for turbine foundations renewable natural resources been considered? What Scoping and compacted for hard-standings. Relatively few non-renewable resources will be measures were explored to firstly avoid these impacts, and Report consumed during operation. where impacts could not be avoided altogether, what • This question will be assessed further during EIA phase. measures were explored to minimise and remedy (including
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“securing ecological sustainable development and use of natural resources”6 Question Answer Reference offsetting) the impacts? What measures were explored to enhance positive impacts? • The WEF will use the renewable energy resource of wind to generate power. • Construction of the WEF will require use of water, a renewable natural resource. Terrestrial Operation of the WEF will consume relatively small quantities of water when compared to Ecology alternative energy technologies such as coal. Scoping • Impacts on the ecosystem caused by use of these renewable energy resources has Report been evaluated during Scoping. Confirmation and/or further study of the identified impacts will be undertaken during EIA. How will this development Does the proposed use and/or impact on development exacerbate the renewable natural resources increased dependency on and the ecosystem of which increased use of resources they are part? Will the use of to maintain economic the resources and/or impact growth or does it reduce on the ecosystem jeopardise resource dependency (i.e. the integrity of the resource Terrestrial de-materialised growth)? • The proposed WEF is predicted to reduce dependency on coal as an energy source. and/or system taking into Ecology (note: sustainability requires • As the WEF will reduce coal resource dependency, this question will not be assessed account carrying capacity Scoping that settlements reduce their further in the EIA phase. restrictions, limits of Report ecological footprint by using acceptable change, and less material and energy thresholds? What measures demands and reduce the were explored to firstly avoid amount of waste they the use of resources, or if generate, without avoidance is not possible, to compromising their quest to minimise the use of improve their quality of life) resources? What measures Does the proposed use of were taken to ensure natural resources constitute responsible and equitable use • The current land use is low-intensity grazing and the land is not suitable for other the best use thereof? Is the of the resources? What agricultural uses. use justifiable when measures were explored to • The proposed development will increase yield as the landowners will be paid for the use Soil Scoping considering intra- and enhance positive impacts? of their land. This could increase other agricultural investments in the area. Report and intergenerational equity, and • The proposed development itself will not cause a significant change in land use, as the Social are there more important development site is primarily low intensity agriculture (grazing), which can still proceed Scoping priorities for which the once the development is constructed. Report resources should be used • The opportunity cost of not proceeding with the proposed development is therefore (i.e. what are the likely to be high. opportunity costs of using these resources this the
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“securing ecological sustainable development and use of natural resources”6 Question Answer Reference proposed development alternative?) Social Do the proposed location, Scoping type and scale of report and • The proposed WEF is predicted to reduce dependency on coal as an energy source. development promote a Terrestrial • This aspect will not be evaluated further in the EIA phase. reduced dependency on Ecology resources? Scoping Report • In terms of best practice guidelines followed by the independent Ecological Specialist, a precautionary and risk-averse approach should be adopted for projects with potential impacts on biodiversity. • In order to adhere to the above principles and best-practice guidelines, the following approach forms the basis for the study approach and assessment philosophy: Terrestrial • The study includes data searches, desktop studies, site walkovers / field survey of the Ecology property and baseline data collection, describing: Scoping • A description of the broad ecological characteristics of the site and its surrounds in Report terms of any mapped spatial components of ecological processes and/or patchiness, patch size, relative isolation of patches, connectivity, corridors, disturbance regimes, ecotones, buffering, viability, etc. How were a risk-averse and • This approach will be used in the EIA phase and further information will also be cautious approach applied in provided during the EIA phase. terms of ecological impacts? • Many fauna are difficult to observe in the field and their potential presence at the site What are the limits of must be evaluated based on the literature and available databases. In many cases, these Terrestrial current knowledge (note: databases are not intended for fine-scale use and the reliability and adequacy of these Ecology the gaps, uncertainties and data sources relies heavily on the extent to which the area has been sampled in the past. Scoping assumptions must be clearly In addition, the consultant has worked extensively in the area, and information from Report stated)? nearby sites is used as and where appropriate. • Further research into the limits of knowledge will form part of the EIA phase. • The risk associated with assumptions and limits of current knowledge is the potential for Terrestrial What is the level of risk information being assessed to be incorrect. This would translate to erroneous impact Ecology associated with the limits of identification and mitigation measures. Scoping current knowledge? • Further research into the level of risk associated with limits of knowledge will form part Report of the EIA phase. • Adopting a risk-averse and cautious approach in all stages of the impact assessment Terrestrial Based on the limits of knowledge and the level of risk, how allows one to minimise the chance of assessing incorrect information and identifying Ecology and to what extent was a risk-averse and cautious approach erroneous impacts. Scoping applied to the development? • This precautionary approach was utilised throughout the Scoping process and will Report continue to be applied in EIA phase.
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“securing ecological sustainable development and use of natural resources”6 Question Answer Reference Negative impacts: e.g. access to resources, opportunity costs, loss of • Throughout the EIA process any negative impacts of the proposed development are amenity (e.g. open space), identified through specialist input. Terrestrial air and water quality • The presented alternatives (turbine locations, and grid connections) will seek to avoid Ecology impacts, nuisance (noise, these negative impacts. Scoping odour, etc.), health impacts, • These will also be considered in the design of the proposed grid connection as well as Report and visual impacts, etc. What the design of the Juno WEF turbine layout. Negative environmental impacts will thus be Social How will the ecological measures were taken to minimised. Mitigation measures will be identified to further minimise negative impacts. Scoping impacts resulting from this firstly avoid negative • Negative impacts will be assessed in the EIA phase. Report development impact on impacts, but if avoidance is • The grid connection alternatives will be assessed in a separate BA process. people’s environmental right not possible, to minimise, in terms following: manage and remedy negative impacts? Positive impacts: e.g. Terrestrial improved access to Ecology resources, improved • Positive impacts are identified and assessed by specialists during the EIA process. Scoping amenity, improved air or Measures to enhance these positive impacts are provided by the specialists. Report and water quality, etc. What • Positive impacts will be assessed in the EIA phase. Social measures were taken to Scoping enhance positive impacts? Report Heritage Scoping • The proposed development of the Juno WEF will create jobs and contribute towards Report, Describe the linkages and dependencies between human socio-economic development in the area. Terrestrial wellbeing, livelihoods and ecosystem services applicable to • The current land use is low-intensity grazing and the land is not suitable for other Ecology the area in question and how the development’s ecological agricultural uses. Scoping impacts will result in socio-economic impacts (e.g. on • The opportunity cost of not proceeding with the proposed development is therefore Report and livelihoods, loss of heritage site, opportunity costs, etc.)? likely to be high. Social • This aspect will be assessed further in the EIA phase. Scoping Report Terrestrial Based on all of the above, how will this development • Negative impacts on ecological integrity from development of the proposed Juno WEF Ecology positively or negatively impact on ecological integrity are predicted to be of low significance with mitigation. Scoping objectives/targets/considerations of the area? • Further ecological impact assessment will be conducted during the EIA phase. Report Considering the need to secure ecological integrity and a Terrestrial • Throughout the EIA process ecological priority areas including sensitive areas and no-go healthy biophysical environment, describe how the Ecology areas in the proposed development site will be identified through specialist input. alternatives identified (in terms of all the different elements Scoping • Further ecological impact assessment and refinement of the project description and of the development and all the different impacts being Report
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“securing ecological sustainable development and use of natural resources”6 Question Answer Reference proposed), resulted in the selection of the “best practicable proposed site layout will be undertaken in the EIA phase. The result of this EIA process environmental option” in terms of ecological considerations? will be considered the “best practicable environmental option”. • Preliminary cumulative impacts are assessed in this report. Should mitigation recommendations supplied by each of the specialists not be applied appropriately the Describe the positive and negative cumulative Terrestrial proposed Juno WEF combined with other facilities proposed in 35 km radius has the ecological/biophysical impacts bearing in mind the size, scale, Ecology potential to have medium significance combined negative cumulative impacts on scope and nature of the project in relation to its location and Scoping biodiversity. existing and other planned developments in the area? Report • Cumulative impacts on ecology and the biophysical environment are to be assessed in more detail during EIA.
Table 4.2 - Socioeconomic Considerations of Need and Desirability for Juno WEF
“promoting justifiable economic and social development”7 Question Answer Reference The IDP (and its sector plans’ vision, objectives, strategies, • The findings of the review indicated that renewable energy is strongly supported at a Social indicators and targets) and any national, provincial and local level. Scoping other strategic plans, • Further policy assessment will be undertaken during the EIA phase. Report frameworks of policies applicable to the area, • The West Coast District Spatial Development Framework (SDF) names energy supply schemes as an objective to be promoted. Spatial priorities and desired • The proposed WEF supports a number of development objectives listed in the West What is the socio- spatial patterns (e.g. need for Coast District Municipality IDP, including: Social economic context of the integrated of segregated • Promotion of economic development and the creation of sustainable job opportunities; Scoping area, based on, amongst communities, need to upgrade • Poverty reduction; Report other considerations, the informal settlements, need for • Development of human and social capital; and following considerations?: densification, etc.), • Provision of adequate infrastructure for economic and social development. • Further spatial planning assessment will be undertaken in the EIA phase. • The proposed development itself will not cause a significant change in land use, as the development site is primarily low intensity agriculture (grazing), which can still proceed Spatial characteristics (e.g. once the development is constructed. Social existing land uses, planned land • The proposed Juno WEF will contribute positively towards the creation of employment Scoping uses, cultural landscapes, etc.), and local economic development, in an area with high levels of unemployment and low Report and levels of economic growth. The area is not suitable for alternative more profitable types of land use.
7Section 24 of The Constitution of South Africa refers.
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“promoting justifiable economic and social development”7 Question Answer Reference • The cumulative impact of the proposed development and other developments in the area on land use is expected to be small. • Further spatial characteristic assessment will be undertaken in the EIA phase. • The Matzikama Municipality IDP notes that the main focus of economic development is to create an inclusive economy that reflects the presence of the broader population of the municipal area with the intent to reduce unemployment and poverty. The promotion of SMME’s is also highlighted as a key area. • The strategic objective is to facilitate development and growth of the local economy of the Matzikama municipal area with the intent to create opportunities that will reduce Municipal Economic Social poverty and unemployment. The relevant strategies include: Development Strategy (“LED Scoping • Instituting programs and projects to create economic growth and development; Strategy”). Report • Providing support for the development and growth of new and existing businesses; • Developing policies to support the growth of an inclusive economy; • Implementing programs and projects to support diversification of the economy; and • Promoting tourism growth and development. • The proposed Juno WEF will contribute positively toward the LED Strategy. • This will be evaluated further during the EIA phase. • Juno WEF is predicted to have a significant and positive impact on the Local Community. • The Socio-Economic Development and Enterprise Development commitments of the REIPPPP require a percentage of gross revenue from the operating wind farm to be invested in education, health, small business development etc. Projects are required to commit at least 1% of gross revenue towards socio-economic development. As an indication, 1% of gross revenue of a hypothetical 140 MW wind farm, with a capacity factor of 35% and a tariff of 80 c/kWh would equal approximately R3.5 m/year (and R68 Considering the socio-economic context, what will the socio- million over the 20 year operation period of a project). Social economic impacts be of the development (and its separate • Projects in the REIPPPP receive additional points if the socio-economic and enterprise Scoping elements/aspects), and specifically also on the socio- development investments are committed to be invested in the Local Community. Report economic objectives of the area? • Juno WEF will create skilled and unskilled jobs, particularly during the construction period. Under the REIPPPP, projects are incentivised to maximise the direct job creation opportunities, particularly for people in the communities surrounding the project. • Juno WEF would also create indirect jobs in accommodation, catering and other services that would support a wind farm and cater for the material and social needs of wind farm workers. • Further study on the predicted socio-economic impacts of the proposed WEF will be undertaken during the EIA phase. Will the development • Juno WEF will contribute toward the MLM LED strategy and skills development Social complement the local socio- programs through the creation of employment and business opportunities, and the Scoping economic initiatives (such as opportunity for skills development and on-site training during both construction and Report
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“promoting justifiable economic and social development”7 Question Answer Reference local economic development operation phases. (LED) initiatives), or skills • Contribution to the LED strategy and skills development programs will be assessed development programs? further during the EIA phase. • The strategic objective of the MLM IDP is to promote responsible and accountable usage of the Municipality’s spatial environment to sustain the natural and built assets. The relevant strategies include: How will this development • Promoting responsible and effective use of the Matzikama coastline; address the specific • Promoting responsible and transparent land use development; physical, psychological, • Encouraging practices to ensure long-term sustainability of the natural resource base. Social developmental, cultural • This includes addressing the issues associated with environmental, social, and economic Scoping and social needs and challenges. Report interests of the relevant • The IDP also identifies potential high impact projects aimed at addressing poverty and communities? unemployment and supporting BBBEE. Of relevance to the proposed development, tourism and support for emerging farmers are identified as an area of high impact. The establishment of a Community Trust can assist to support emerging farmers. • This aspect will be assessed further in the EIA phase. Will the development result in equitable (intra- and inter- • According to The Green Jobs Study the proposed Juno WEF is expected to socially and Social generational) impact distribution, in the short- and long- economically sustainable in the short and long term. Scoping term? Will the impact be socially and economically • The degree to which this positive impact may be expected and enhanced will be Report sustainable in the short- and long-term? descried further in the EIA phase. result in the creation of residential and employment • The proposed development of the Juno WEF will create local jobs and contribute Social opportunities in close proximity towards socio-economic development in the area. Scoping to or integrated with each • This aspect will be assessed further by the Social Specialist in the EIA phase. Report other, • The need for transport of people and goods will be increased during construction of the Juno WEF. In terms of location, • Lower per capita carbon footprints are predicted due to the commercial forms of Social reduce the need for transport of describe how the transport that will be employed to move the workforce (e.g. public transport, contractor Scoping people and goods, placement of the buses). Report proposed development • This aspect will be evaluated in detail during the EIA phase. A Transport Management will: Plan will form part of the EIA phase. • During the construction phase opportunities will be created for local transport result in access to public companies. transport or enable non- • The need for transport of people and goods will be increased during construction. Social motorised and pedestrian • Lower per capita carbon footprints are predicted due to the commercial forms of Scoping transport (e.g. will the transport that will be employed to move the workforce (e.g. public transport, contractor Report development result in buses). densification and the • A Transport Management Plan will form part of the EIA phase.
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“promoting justifiable economic and social development”7 Question Answer Reference achievement of thresholds in terms public transport), • Local communities and their service providers will benefit from the socio-economic Social compliment other uses in the development provided by the WEF. Scoping area, • The Social Specialist will evaluate this aspect further in the EIA phase. Report • The proposed WEF is in line with applicable international, national, provincial and local Social be in line with the planning for planning strategies. Scoping the area, • This aspect has been covered within the Scoping Report and will not be assessed Report further during EIA phase. for urban related development, • The proposed development occurs approximately 5 km beyond the urban edge of the Social make use of underutilised land nearest town, Strandfontein. Scoping available with the urban edge, • This aspect is not applicable and will not be evaluated further during the EIA phase. Report • Existing access roads will be utilised wherever possible. • The existing Eskom Juno substation has the capacity to support this development and will be utilised for grid connection. • It is expected that any construction water required will be delivered by tankers. A borehole may be considered as a source for construction water, in which case a WULA Social optimise the use of existing will be submitted to DWS. Scoping resources and infrastructure, • Waste removal will be in accordance with best practice as per the EMPr by qualified Report waste removal contractors to the nearest registered landfill. • Portable sanitation facilities will be utilised during construction, so that no connection to the local sewerage system will be required. • Any additional infrastructure required will be constructed by the developer. • This aspect will be assessed further in EIA phase. opportunity costs in terms of bulk infrastructure expansions in non-priority areas (e.g. not • No opportunity costs in terms of bulk infrastructure expansions in non-priority areas are Social aligned with the bulk predicted due to the proposed development. Scoping infrastructure planning for the • The proposed WEF is not located within a bulk infrastructure expansion area. Report settlement that reflects the • This aspect will not be evaluated further in the EIA phase. spatial reconstruction priorities of the settlement), discourage "urban sprawl" and • Construction of Juno WEF approximately 5 km north east of the nearest town, Social contribute to Strandfontein, is likely to increase low density urban sprawl. Scoping compaction/densification, • This landscape impact will be assessed further in the EIA phase. Report contribute to the correction of Social the historically distorted spatial • The existing Eskom Juno substation will be utilised for connection to the national grid. Scoping patterns of settlements and to • This aspect will not be assessed further during the EIA phase. Report the optimum use of existing
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“promoting justifiable economic and social development”7 Question Answer Reference infrastructure in excess of current needs, • Construction of the renewable energy Juno WEF project will assist South Africa in encourage environmentally transitioning from a carbon-intensive resource use economy to a sustainable low carbon Social sustainable land development footprint economy. Scoping practices and processes, • Sustainable land development is an overarching aspect of the proposed project Report development and will be detailed further in the EIA phase. • Wind resources on the proposed WEF site are suitable for an economically feasible wind take into account special farm. locational factors that might • A grid connection option is available approximately 16 km to the north east - the Social favour the specific location (e.g. existing Eskom Juno substation. Scoping the location of a strategic • Access to the site is readily available via the R362 and an existing gravel farm road of Report mineral resource, access to the approximately 2 km. port, access to rail, etc.), • Locational aspects will be assessed further in the EIA phase. the investment in the settlement or area in question • The proposed development will create jobs and contribute towards socio-economic Social will generate the highest socio- development in an area that does not have high economic potential. Scoping economic returns (i.e. an area • The WEF is likely to result in significant positive socio-economic opportunities. Report with high economic potential), impact on the sense of history, sense of place and heritage of • The sense of place of the wider region is commonly associated with natural resources Social the area and the socio-cultural and intensive and extensive agriculture uses. Scoping and cultural-historic • Socio-cultural and cultural-historic characteristics and sensitivities of the area will be Report characteristics and sensitivities assessed further in the EIA phase with input from Heritage and Visual Specialists. of the area, and in terms of the nature, scale • The proposed Juno WEF aligns with the Matzikama Municipality LM’s IDP. One of the and location of the development Social strategies of the MMLM IDP is implementing an integrated human settlement plan. promote or act as a catalyst to Scoping • Thus the proposed development is predicted to support the creation of a more create a more integrated Report integrated settlement and this aspect will not be assessed further in the EIA phase. settlement? What are the limits of current • The independent Social Specialist has not yet interacted with key stakeholders. This is Social knowledge (note: the gaps, considered the main limit of current knowledge. Scoping uncertainties and assumptions • A site visit will be conducted in the EIA phase. Limitations and assumptions will be How were a risk-averse Report must be clearly stated)? updated at this stage. and cautious approach What is the level of risk (note: applied in terms of socio- • The risk due to limits of current knowledge is considered to be low due to the positive related to inequality, social Social economic impacts?: socioeconomic impact expected from the proposed WEF. fabric, livelihoods, vulnerable Scoping • The level of risk due to limits of current knowledge will be assessed further with communities, critical resources, Report specialist input in the EIA phase. economic vulnerability and
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“promoting justifiable economic and social development”7 Question Answer Reference sustainability) associated with the limits of current knowledge? Based on the limits of knowledge and the level of risk, • The approach to the SIA study is based on the Western Cape Department of Social how and to what extent was a Environmental Affairs and Development Planning Guidelines for Social Impact Assessment Scoping risk-averse and cautious (DEADP, 2007). Report approach applied to the • To be assessed further in EIA phase. development? • Negative impacts were identified by the Social Specialist. These include: • Impacts associated with the presence of construction workers on site and in the area; Negative impacts: e.g. health • Influx of job seekers to the area; (e.g. HIV-Aids), safety, social • Increased safety risk to farmers, risk of stock theft and damage to farm infrastructure How will the socio- ills, etc. What measures were associated with presence of construction workers on the site; Social economic impacts taken to firstly avoid negative • Increased risk of grass fires; Scoping resulting from this impacts, but if avoidance is not • Impact of heavy vehicles, including damage to roads, safety and dust; Report development impact on possible, to minimise, manage • Impact on farming activities. people’s environmental and remedy negative impacts? • Mitigation measures are provided in the Social Impact Assessment Scoping Report. right in terms following: • Negative impacts and associated mitigation measures will be studied further in the EIA phase. Positive impacts. What • Creation of employment and business opportunities, and the opportunity for skills Social measures were taken to development and on-site training. Scoping enhance positive impacts? • Further enhancement possibilities will be explored in the EIA phase. Report Social Considering the linkages and dependencies between human Scoping wellbeing, livelihoods and ecosystem services, describe the • Some impacts are expected on ecological processes, vegetation and fauna. These Report and linkages and dependencies applicable to the area in question impacts are considered to be of low significance and manageable. Terrestrial and how the development’s socio-economic impacts will • Ecological and Social Specialists will evaluate this aspect further in the EIA phase. Ecology result in ecological impacts (e.g. over utilisation of natural Scoping resources, etc.)? Report • All applicable planning policies were considered in this Scoping Report. What measures were taken to pursue the selection of the • The proposed Juno WEF fits with all planning policies. Social “best practicable environmental option” in terms of socio- • Further research will be conducted as part of the EIA phase to ensure that the Juno Scoping economic considerations? WEF is the "best practicable environmental option” in terms of socio-economic Report considerations. What measures were Considering the need for social • The proposed Juno WEF aligns with a variety of planning policies that consider taken to pursue equity and justice, do the Social environmental and spatial justice. environmental justice so alternatives identified, allow the Scoping • Due to the planning fit of the proposed Juno WEF to all applicable policies this aspect that adverse “best practicable environmental Report will not be evaluated further in EIA phase. environmental impacts option” to be selected, or is
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“promoting justifiable economic and social development”7 Question Answer Reference shall not be distributed in there a need for other such a manner as to alternatives to be considered? unfairly discriminate against any person, particularly vulnerable and disadvantaged persons (who are the beneficiaries and is the development located appropriately)? What measures were taken to pursue equitable access to • The proposed Juno WEF will contribute to equitable access by supplying electricity to environmental resources, benefits and services to meet basic the national grid, and by providing local and regional socioeconomic benefits in terms of Social human needs and ensure human wellbeing, and what special the REIPPPP Economic Development requirements. Scoping measures were taken to ensure access thereto by categories • Further information to be provided as part of the EIA phase and Social Impact Report of persons disadvantaged by unfair discrimination? Assessment. What measures were taken to ensure that the responsibility • Construction, operation and decommissioning of the proposed Juno WEF will be done for the environmental health and safety consequences of the according to environmental health and safety legislative requirements and applicable
development has been addressed throughout the guidelines. development’s life cycle? • Further information will be provided during the EIA phase. NEMA: EIA Regulations (2014) as • Public participation is being undertaken according to NEMA: EIA Regulations (2014) as amended ensure the participation of all amended and DEA (2017) Public Participation Guidelines. and DEA interested and affected parties, • Further information on PPP to be provided during the EIA phase. (2017) Public Participation Guidelines What measures were provide all people with an taken to: opportunity to develop the • The proposed Juno WEF PPP is being undertaken in terms of legislative requirements Social understanding, skills and and best practise guidelines. Scoping capacity necessary for achieving • A Public Meeting was held to present the findings of the Scoping Report. Report equitable and effective • Further information on PPP to be provided during the EIA phase. participation, • The PPP is being undertaken according to best practise guidelines. ensure participation by Social • Notification of initiation of the PPP was provided in all required channels, i.e. newspaper vulnerable and disadvantaged Scoping adverts, site notices and written notifications. persons, Report • Further information on PPP to be provided during the EIA phase.
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“promoting justifiable economic and social development”7 Question Answer Reference promote community wellbeing and empowerment through • The proposed Juno WEF fits into the various planning policies including the MLM IDP. environmental education, the Social • Contribution to the MLM IDP and implementation of a Community trust will assist the raising of environmental Scoping local strategies, including improving education facilities and youth development. awareness, the sharing of Report • Further information to be provided in EIA phase. knowledge and experience and other appropriate means, ensure openness and • Legislative requirements and best practise guidelines will be followed throughout the Social transparency, and access to process. Scoping information in terms of the • Further information to be provided in EIA phase. Report process, ensure that the interests, needs and values of all interested and affected parties were taken into • A Social Impact Assessment forms part of the EIA process. The independent Social Social account, and that adequate Specialist will ensure that all needs and values are taken into account. Scoping recognition were given to all • Further information to be provided in the EIA phase. Report forms of knowledge, including traditional and ordinary knowledge, and ensure that the vital role of women and youth in • The Social Impact Assessment and PPP that are conducted according to legislation and environmental management guidelines will ensure that women and youth are recognised and involved in the process. Social and development were • REIPPPP requirements place specific responsibilities on IPPs in terms of women and Scoping recognised and their full youth development. Report participation therein were be • Further information to be provided in the EIA phase. promoted? Considering the interests, needs and values of all the interested and affected parties, describe how the development will allow for opportunities for • The proposed WEF has a good planning fit with all applicable policies and will result in Social all the segments of the substantial local socioeconomic opportunities. Scoping community (e.g.. a • Further information to be provided in the EIA phase. Report mixture of low-, middle-, and high-income housing opportunities) that is consistent with the priority needs of the local area (or
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“promoting justifiable economic and social development”7 Question Answer Reference that is proportional to the needs of an area)? What measures have been taken to ensure that current and/or future workers will be informed of work that potentially might be harmful to • Future workers on the proposed Juno WEF will be educated on their rights to refuse Social human health or the work. Scoping environment or of dangers • More information will be provided in the EIA phase. Report associated with the work, and what measures have been taken to ensure that the right of workers to refuse such work will be respected and protected? the number of temporary versus • The majority of employment opportunities will be realised in the construction phase. Of Social permanent jobs that will be these the majority will be temporary positions. Scoping created, • Further information to be supplied in EIA phase. Report whether the labour available in the area will be able to take up • Low and Semi-Skilled employment opportunities will be available during construction of Social the job opportunities (i.e. do the proposed Juno WEF. Scoping the required skills match the • This aspect will thus not be evaluated further in the EIA phase. Report skills available in the area), Describe how the • It is expected that most workers will reside in the nearby towns. Social the distance from where development will impact • Due to the short travel distance predicted this aspect will not be assessed further in the Scoping labourers will have to travel, on job creation in terms EIA phase. Report of, amongst other the location of jobs aspects: opportunities versus the • Local and equitable distribution of costs and benefits is expected for the proposed Juno Social location of impacts (i.e. WEF. Scoping equitable distribution of costs • Further information will be provided on this aspect during the EIA phase. Report and benefits), and the opportunity costs in terms • Opportunity costs of the proposed Juno WEF are expected to be of low significance due of job creation (e.g. a mine Social to the lack of alternative options at the proposed site. might create 100 jobs, but Scoping • Opportunity costs would be realised if the proposed development did not occur. impact on 1000 agricultural Report • Opportunity costs will be evaluated further in the EIA phase. jobs, etc.).
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“promoting justifiable economic and social development”7 Question Answer Reference that there were • All applicable planning policies and legislation were considered in this Scoping Report. intergovernmental coordination Social • The proposed Juno WEF fits with all planning policies. and harmonisation of policies, Scoping • This aspect has been covered fully during the Scoping phase and will not be evaluated legislation and actions relating Report What measures were further in the EIA phase. to the environment, and taken to ensure: that actual or potential conflicts • All interested and affected organs of state were pre-identified and registered on the Social of interest between organs of Juno WEF I&AP Database. As registered I&APs all public correspondence including Scoping state were resolved through notifications of report availability will be provided. Report conflict resolution procedures? • This aspect will be assessed further in the EIA phase. What measures were taken to ensure that the environment will be held in public trust for the people, that the beneficial Social • The proposed Juno WEF aims to uphold the principles of sustainable development. use of environmental resources will serve the public interest, Scoping • Further information will be provided in the EIA phase. and that the environment will be protected as the people’s Report common heritage? Social Scoping • Specialist input provides realistic mitigation measures. Are the mitigation measures proposed realistic and what Report and • Rehabilitation to be undertaken after decommissioning of the proposed Juno WEF will long-term environmental legacy and managed burden will be Terrestrial significantly reduce any potential legacy effects. left? Ecology • This aspect will be assessed further in the EIA phase. Scoping Report Social What measures were taken to ensure that he costs of Scoping remedying pollution, environmental degradation and • The proposed Juno WEF aims to reduce pollution and promote sustainable Report and consequent adverse health effects and of preventing, development. Terrestrial controlling or minimising further pollution, environmental • The NEMA provides the context for remediating environmental damage; thus this Ecology damage or adverse health effects will be paid for by those aspect will not be assessed further in the EIA phase. Scoping responsible for harming the environment? Report Considering the need to secure ecological integrity and a Social healthy bio-physical environment, describe how the • The proposed site and alternatives have undergone several changes to avoid, mitigate Scoping alternatives identified (in terms of all the different elements or minimise potential negative environmental impacts. Report and of the development and all the different impacts being • Further refinement and update of the project description and site layout will be Terrestrial proposed), resulted in the selection of the best practicable undertaken in the EIA phase, in an effort to select the best practicable environmental Ecology environmental option in terms of socio-economic option in terms of socio-economic considerations. Scoping considerations? Report Describe the positive and negative cumulative socio- • It is likely that the proposed development will have negative and positive socioeconomic Social economic impacts bearing in mind the size, scale, scope and cumulative impacts. Scoping nature of the project in relation to its location and other • Cumulative impacts will be assessed further in the EIA phase. Report planned developments in the area?
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4.1 Wind Resource at Juno WEF Wind energy projects are characterised by a number of additional factors, besides the wind resource, that make a particular site a viable alternative. These include topography, proximity to and capacity of the national electricity grid, site accessibility, availability of land and land use, as well as possible environmental and permitting constraints. The site selection process undertaken for this project took into account a high-level assessment of various opportunities and constraints which may be applicable at a regional level before narrowing its focus on potential individual wind energy facilities at a local and site specific level. The wind resource in the area and on this site specifically is competitive by national and international comparison. This is evidenced by data collected by an on-site meteorological mast. Wind power density directly determines cost efficiency in using wind energy. The wind power density, measured in watts per square meter, indicates how much energy is available at the site for conversion by a wind turbine. The density is categorised as poor (<150 Watt/m2), fair (150 - 250 Watt/m2), good (250 - 350 Watt/m2), or excellent (>350 Watt/m2). In terms of the mean wind power density of the project site, the Western Cape Department of Agriculture (2018) estimate the density to be in the order of 320-440W/m², which makes the project site excellent in terms of possible wind energy generation. Based on their preliminary assessment of the wind resource from these measurements, AMDA Developments has determined that the proposed development would generate sufficient energy to support an economically viable wind energy project.
4.2 Wind Energy Facilities Contribution to Mitigating Climate Change The scientific consensus is that climate is changing and that these changes are in large part caused by 8 human activities . Of these human activities, increase in carbon dioxide (CO2) levels due to emissions from fossil fuel combustion is regarded as a significant contributor to anthropogenic climate change.
South Africa is one of the world's largest emitters of CO2 in absolute and per capita terms. The following climate change impacts have been predicted in relation specifically to South Africa9: South Africa’s coastal regions will warm by around 1 - 2°C by about 2050 and around 3 - 4°C by about 2100; South Africa’s interior regions will warm by around 3 - 4°C by about 2050 and around 6 - 7°C by about 2100; There will be significant changes in rainfall patterns and this, coupled with increased evaporation, will result in significant changes in respect of water availability; Our biodiversity will be severely impacted, especially the grasslands, fynbos and succulent Karoo where a high level of extinction is predicted; Small scale and homestead farmers in dry lands are most vulnerable to climate change and although intensive irrigated agriculture is better off than these farmers, irrigated lands remain vulnerable to reductions in available water; Some predictions suggest that maize production in summer rainfall areas and fruit and cereal production in winter rainfall areas may be badly affected; Commercial forestry is vulnerable to an increased frequency of wildfires and changes in available water in south-western regions; Rangelands are vulnerable to bush encroachment which reduces grazing lands; Alien invasive plant species are likely to spread more and have an ever-increasing negative impact on water resources; Although strong trends have already been detected in our seas, including rising sea levels and the warming of the Agulhas current and parts of the Benguela current, we are not yet sure what impacts these could have on our seas, the creatures living in the seas or on the communities dependant on the sea; Because of our already poor health profile, South Africans are specifically vulnerable to new or exacerbated health threats resulting from climate change. For example, some effects of climate change may already be occurring due to changes in rainfall (droughts and floods) and temperature extremes and cholera outbreaks have been associated with extreme weather events, especially in poor, high density settlements; and
8 http://adsabs.harvard.edu/abs/2013ERL.....8b4024C. 9 http://www.cop17-cmp7durban.com/en/south-africa-on-climate-change/effects-of-climate-change-on-south-africa.html.
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There will be an increase in the frequency and severity of extreme weather events. Damage costs due to extreme weather-related events (flooding, fire, storms and drought) have already been conservatively estimated at being roughly 1 billion rand per year. As explained in National Treasury's Carbon Tax Policy Paper (May 2013)10, addressing the challenges of climate change through facilitating a viable and fair transition to a low-carbon economy is essential to ensure an environmentally sustainable economic development and growth path for South Africa. Further the Policy Paper states that the South African government is of the view that South Africa needs to reduce its greenhouse gas emissions while working to ensure economic growth, increase employment, and reduce poverty and inequality11. Renewable energy projects will play a significant role in meeting South Africa’s targets in accordance with the Paris Agreement and assisting the transition to a low-carbon economy. Renewable energy is valuable to the environment because these projects displace energy produced by fossil fuel (dirty coal, dirty gas, diesel etc.) and nuclear energy (risky and costly with almost perpetual and dangerous by-products) sources. A renewable energy project injects electrical energy into the grid and this energy becomes mixed with the energy produced by all the sources feeding into the grid. The effect is that less fossil and nuclear fuel is required to keep the grid balanced if you increase the fraction of renewable energy entering the grid. For every kilowatt hour (kWh) that Eskom produces from fossil fuels, Eskom also creates about 1.1 kg of carbon dioxide (a gas strongly associated with global warming). In other words, if you use 450 kWh electrical energy at your home per month you are adding approximately half a ton (500 kg) to the concentration of carbon dioxide in the atmosphere.
4.3 Diversification and Decentralisation of Supply With its abundant coal supplies, approximately 89% of South Africa's energy needs are currently met through coal-fired generators, with nuclear energy contributing approximately 5% and the balance by pumped storage and hydroelectric (3.6%), renewable energy (2.4%) and gas turbines (0.1%). Electricity generation is dominated by state-owned power company Eskom, which currently produces over 96.7% of the power used in the country. A diversification of energy supplies and producers, particularly with respect to renewable energy sources, would lead to greater energy security and economic and environmental benefits. The deployment of various renewable technologies increases the diversity of electricity sources and, through local decentralised generation, contributes to the flexibility of the system and its resistance to central shocks. According to the International Energy Agency, "renewable energy resources ... exist virtually everywhere, in contrast to other energy sources, which are concentrated in a limited number of countries. Reduced energy intensity, as well as geographical and technological diversification of energy sources, would result in far-reaching energy security and economic benefits."12 Progress in this regard has been made under the DoE REIPPPP, with 79 approved wind, solar, small hydro and bioenergy projects at various stages of development in the first four bidding windows of the REIPPPP, including 5243 MW of wind power. According to the DoE’s Integrated Resource Plan for Electricity 2010- 2030, South Africa is aiming to procure 9200 MW of wind power by 2030.
4.4 Reduced Cost of Energy In terms of cost, wind energy is globally one of the cheapest forms of new generation capacity available13. Under the REIPPPP, the fully-indexed tariffs for wind energy projects have dropped from R1.15/kilowatt hour (kWh) to as low as 62c/kWh, representing globally very competitive prices for energy generation. With Eskom currently producing power at 60c/kWh and with electricity from the coal-fired power stations currently under construction expected to cost more than R1.00/kWh, wind energy is one of the lowest cost forms of new generation capacity in South Africa. In addition to the levelled cost of developing, financing, constructing, operating and decommissioning energy generating facilities, all energy generators produce an external cost (or externality) such as the
10 National Treasury Carbon Tax Policy Paper. Available online http://www.treasury.gov.za/public%20comments/Carbon%20Tax%20Policy%20Paper%202013.pdf 11 http://www.treasury.gov.za/public%20comments/Carbon%20Tax%20Policy%20Paper%202013.pdf 12 www.iea.org/textbase/npsum/ETP2012SUM.pdf 13 https://www.esi-africa.com/renewable-energy-costs-less-far-making-logical-choice
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additional indirect costs incurred by society and the environment, including health, climate change, environmental, mining and water costs. WEFs produce relatively small external costs when compared to other energy generation technologies. Any externalities can be considered positive in the form of local ownership of the project, local job creation and zero pollution resulting from wind facilities.
4.5 Economic Development and Job Creation The REIPPPP requires Economic Development (“ED”) commitments from onshore wind energy projects and projects are adjudicated according to their ED commitments. The main ED beneficiaries of approved projects are currently communities living within a 50 km radius of renewable energy facilities. Projects are bid and thereafter adjudicated according to tariff (70%) and Economic Development (30%). There is therefore an incentive for projects to focus on Economic Development of the Local Community and to assign as much revenue, jobs, procurement etc. to local people as well as South African companies and people as possible in order to stand a chance of having a successful project. Projects are adjudicated according to the following points: Economic Development Elements Weighting
Job Creation 25% Local Content 25% Ownership 15% Management Control 5% Preferential Procurement 10% Enterprise Development 5% Socio-Economic Development 15% Total 100% Total points 30 points
A number of these elements will have a significant and positive impact on the Local Community. In terms of job creation, bidders are required to indicate the actual number of jobs that will be created for South African citizens, Skilled People, Black People, Skilled Black People and Citizens from the Local Communities. Significant skilled and unskilled job opportunities will be created in the Local Communities, particularly during the construction period. For Ownership, bidders are required to indicate the total shareholding of the Project Company in the hands of Black People and Local Communities. The minimum ownership percentage for Local Community is 2.5% but projects have committed up to 40% Local Community Ownership in order to have a competitive project. Broad-based community trusts are established as a vehicle for Local Community Ownership to received dividend revenue from an operating project that will be invested in socio-economic development imperatives as determined by trustees. The ownership stake is funded either through debt or through equity partners (“a free-carry”). The Socio-Economic Development and Enterprise Development commitments require a percentage of gross revenue from the operating wind farm to be invested in education, health, small business development etc. Projects are required to commit at least 1% of gross revenue towards socio-economic development. As an indication, 1% of gross revenue of a hypothetical 140 MW wind farm, with a capacity factor of 35% and a tariff of 80 c/kWh would equal approximately R3.5 m/year (and R68 million over the 20 year operation period of a project). Projects in the REIPPPP receive additional points if the socio- economic and enterprise development investments are committed to be invested in the Local Community. WEFs in South Africa will create skilled and unskilled jobs, particularly during the construction period. Under the REIPPPP, projects are incentivised to maximise the direct job creation opportunities, particularly for people in the communities surrounding the project. WEFs tend to be constructed in rural areas with small communities and limited infrastructure and social amenities. A wind farm would create indirect jobs in accommodation, catering and other services that would support a wind farm and cater for the material and social needs of wind farm workers.
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Localisation is considered one of the major contributors to job creation and general improvement of the economy of South Africa. Localisation through the construction of new manufacturing facilities to build wind turbine towers and other turbine components in South Africa is currently progressing. Wind energy can provide technical skills to South Africans and thus improve the technical skills profile of the country and the regions where wind energy facilities are located. Through the REIPPPP, developers’ own initiatives and through support from international donor agencies, a number of young South Africans are being trained on various aspects of wind farm construction and operation. These projects, if successfully implemented, have the potential to transform for the better key development areas of South Africa and would assist South Africa in meeting its development goals, while meeting its carbon emission reduction targets as per international protocols.
4.6 Policies in Support of Renewable Energy The Social Scoping Report provides a detailed review of the Policies in Support of Renewable Energy. A summarised list of the policies and planning documents in support of renewable energy is provided below: National Policy and Planning Renewable Energy Independent Power Producer Procurement Programme (REIPPPP) National Energy Act (Act 34 of 2008) White Paper on the Energy Policy of South Africa White Paper on Renewable Energy National Integrated Resource Plan for Electricity (2010 – 2030) National Development Plan The New Growth Path Framework National Infrastructure Plan Strategic Integrated Project (SIP) 8 Green Energy in Support of the South African Economy SIP 9 Electricity Generation to Support Socio-Economic Development SIP 10 Electricity Transmission and Distribution Provincial and Local Policy Western Cape Provincial Spatial Development Framework Western Cape Provincial Climate Change Response Strategy (PCCRS) West Coast Municipality Integrated Development Plan Matzikama Municipality Integrated Development Plan White Paper on Sustainable Energy for the Western Cape Provincial Strategic Plan 2014-2019 Western Cape Land Use Planning Act Western Cape Infrastructure Framework Western Cape Green Economy Strategy Framework One Cape 2040 Strategy Western Cape Amended Zoning Scheme Regulations for Commercial Renewable Energy Facilities Strategic Initiative to Introduce Commercial Land Based Wind Energy Development to the Western Cape – Towards a Regional Methodology Guideline for the Development on Mountains, Hills and Ridges in the Western Cape
4.7 Need and Desirability Conclusion The need for the proposed development is supported in terms of meeting the country’s climate change goals, and in terms of reducing the country’s dependence on fossil fuels as the main source of meeting the country’s electricity requirements. Both national and provincial policies and planning documents support the development of renewable energy facilities. The need and desirability for these types of developments play a role in meeting energy and climate change targets and also provide a socioeconomic boost at the local level in areas that are in need of it.
5 ENVIRONMENTAL LEGISLATION
5.1 The National Environment Management Act, 1998 (Act 107 of 1998) Section 2 of the National Environment Management Act, 1998 (NEMA) as amended, lists environmental principles that are to be applied by all organs of state regarding proposals that may significantly affect the environment. Included amongst the key principles is the principle that all development must be socially, economically and environmentally sustainable, environmental management must place people and their
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needs at the forefront of its concern, to serve their physical, psychological, developmental, cultural and social interests equitably. NEMA also provides for the participation of I&APs and it stipulates that decisions must take the interests, needs and values of all I&APs into account. Chapter 5 of NEMA outlines the general objectives and implementation of Integrated Environmental Management (IEM), the latter providing a framework for the integration of environmental issues into the planning, design, decision-making and implementation of plans and development proposals. Section 24 provides a framework for the granting of environmental authorisations. In order to give effect to the general objectives of IEM, the potential impacts on the environment of listed activities must be considered, investigated, assessed and reported to the competent authority. Section 24(4) outlines the minimum requirements for procedures for the investigation, assessment and communication of the potential impact of activities. On 7 April 2017 the Minister of Environmental Affairs published amendments to the NEMA: EIA Regulations of 2014 (GNR 326) and the three Listing Notices (GNR 324, 325 and 327) in Government Gazette No. 40772. This amendment was promulgated under the NEMA: EIA Regulations 2014 published by the Minister of Environmental Affairs in Government Gazette No. 38282 on 8 December 2014. The 2014 EIA Regulations in turn were promulgated under the requirements of Chapter 5 of the NEMA. The EIA Regulations 2014 as amended by GNR 326 of 2017 provide for the control of certain Listed Activities. These activities are listed in Government Notice No. R327 (Listing Notice 1 – Basic Assessment), R325 (Listing Notice 2 – Scoping & EIA Process) and R324 (Listing Notice 3 – Basic Assessment) of 7 April 2017, and are prohibited to commence until environmental authorisation has been obtained from the competent authority, in this case, the Department of Environmental Affairs (DEA). The DEA is the competent authority for all renewable energy proposals, as NEMA states that: “24C. (2) The Minister must be identified as the competent authority in terms of subsection (1) if the activity- (a) has implications for international environmental commitments or Relations; ….(c) has a development footprint that falls within the boundaries of more than one province or traverses international boundaries.” This project has implications for international environmental commitments that South Africa has made in terms of climate change and the proposed development site is located in one province the Western Cape. Environmental authorisation, which may be granted subject to conditions, will only be considered upon compliance with GNR982, as amended by GNR326 of 7 April 2017. The Listed Activities applicable to this proposed project are presented in Table 5.1 below. All potential impacts associated with these Listed Activities will be considered and adequately assessed in this EIA process. As this proposal triggers Listed Activities in Listing Notices 1 – 3, a full Scoping and EIA process is to be followed for this application. Any Environmental Authorisation obtained from the DEA applies only to those specific listed activities for which the application was made. To ensure that all Listed Activities that could potentially be applicable to this proposal are covered by the Environmental Authorisation, a precautionary approach is followed when identifying listed activities, that is, if an activity could potentially be part of the proposed development, it is listed. Table 5.1 below indicates the listing notices as amended in 2017.
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Table 5.1: NEMA Listed Activities in Relation to the Proposed Development Listing Notices 1 Listed Activity Description of project activity that triggers - 3 listed activity 07 April 2017 Listing Notice 1 The development of facilities or Electrical reticulation will be installed to GN R 327 infrastructure for the transmission and transfer electricity from the turbines to an Activity 11 distribution of electricity— on-site substation. Cables will be installed (i) outside urban areas or industrial underground where feasible. These internal complexes with a capacity of more than transmission lines are expected to be of 33 33 but less than 275 kilovolts. kV capacity. Listing Notice 1 The development and related operation Construction of the WEF will require GN R 327 of facilities or infrastructure, for the dangerous goods in the form of hydrocarbon Activity 14 storage, or fuels (e.g. diesel), paints and solvents, oils for the storage and handling, of a and greases. Sewage and waste streams dangerous good, where such storage will be generated by the WEF. During occurs in construction of the WEF in particular the containers with a combined capacity of combined capacity of dangerous goods on 80 cubic metres or more but not site may exceed 80 cubic metres. The exceeding 500 proposed on-site substation is likely to cubic metres. require the use of transformer oils/other hazardous substances during the operational phase. Listing Notice 1 The infilling or depositing of any The construction of the WEF would likely GN R 327 material of more than 10 cubic metres include the excavation of soil in Activity 19 into, or the dredging, excavation, watercourses/drainage line areas, and removal or moving of soil, sand, shells, infilling/deposition may exceed 5 cubic shell grit, pebbles or rock of more than metres and in some instances may exceed 10 cubic metres from a watercourse; 10 cubic metres. Borrow pits for the sourcing of aggregate material may be required. The location of these in relation to watercourses will be determined during the EIA. The construction of associated infrastructure, such as access tracks crossing watercourses may require excavation and/or infilling of watercourse areas. The extent and location of this activity will be clarified during the EIA. Listing Notice 1 The development of a road— Access roads of 6 - 12 m will be required GN R 327 (ii) with a reserve wider than 13,5 between turbines. Activity 24 meters, or where no reserve exists where the road is wider than 8 metres; Listing Notice 1 The expansion of— Existing bridges over watercourses may GN R 327 (i) infrastructure or structures where need to be expanded or widened. Activity 48 the physical footprint is expanded by 100 square metres or more; where such expansion occurs— (a) within a watercourse; (b) in front of a development setback; or (c) if no development setback exists, within 32 metres of a watercourse, measured from the edge of a watercourse; Listing Notice 1 The widening of a road by more than 6 Existing farm access roads may need to be GN R 327 metres, or the lengthening of a road by widened or lengthened. These roads would Activity 56 more than 1 kilometre- currently have no road reserve and may be (ii) where no reserve exists, where the wider than 8 m in some areas. existing road is wider than 8 metres;
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Listing Notice 2 The development of facilities or The WEF will consist of a number of wind GN R 325 infrastructure for the generation of turbines for electricity generation with a Activity 1 electricity from a renewable resource combined capacity of more than 20 MW. where the electricity output is 20 megawatts or more. Listing Notice 2 The clearance of an area of 20 hectares The construction of the WEF may require the GN R 325 or more of indigenous vegetation, clearance of more than 20 hectares of Activity 15 excluding where such clearance of vegetation in total across the site. indigenous vegetation is required for- (i) the undertaking of a linear activity; Listing Notice 3 The development of a road wider than Internal and external access roads will be GN R 324 4 metres with a reserve less than 13,5 constructed, which are wider than 4 m. The Activity 4 metres. site falls outside of an urban area and i. Western Cape contains indigenous vegetation. i. Outside urban areas: (aa) Areas containing indigenous vegetation; Listing Notice 3 The clearance of an area of 300 square The proposed development will require the GN R324 metres or more of indigenous clearance of natural vegetation in excess of Activity 12 vegetation except where such clearance 300 m2 in areas of natural vegetation. Parts of indigenous vegetation is required for of the site fall within Critical Biodiversity maintenance purposes undertaken in Areas. accordance with a maintenance management plan. i. Western Cape i. Within any critically endangered or endangered ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list, within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004; ii. Within critical biodiversity areas identified in bioregional plans; Listing Notice 3 The development of— Bridges and infrastructure may be GN R324 (ii) infrastructure or structures with a constructed within 32 m of watercourse(s). Activity 14 physical footprint of 10 square metres The site lies outside of an urban area and a or more; portion of the site is a Critical Biodiversity where such development occurs— (a) within a watercourse; (c) if no development setback has been adopted, within 32 metres of a watercourse, measured from the edge of a watercourse; i. Western Cape i. Outside urban areas: (ff) Critical biodiversity areas or ecosystem service areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans; Listing Notice 3 The widening of a road by more than 4 Existing farm roads may need to be widened GN R324 metres, or the lengthening of a road by or lengthened. The site lies outside urban Activity 18 more than 1 kilometre areas, and contains indigenous vegetation. i. Western Cape ii. All areas outside urban areas: (aa) Areas containing indigenous vegetation; Listing Notice 3 The expansion of— The construction of the WEF may include the GN R324 expansion of existing bridges over Activity 23 watercourses. The site lies outside of any
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(ii) infrastructure or structures where urban area, and parts of the site fall within a the physical footprint is expanded by 10 Critical Biodiversity Area. square metres or more; where such expansion occurs— (a) within a watercourse; (c) if no development setback has been adopted, within 32 metres of a watercourse, measured from the edge of a watercourse; i. Western Cape i. Outside urban areas: (ee) Critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans;
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5.2 The National Heritage Resources Act, 1999 (Act No. 25 of 1999) Section 38 (1) of the National Heritage Resources Act, 1999 (NHRA) lists development activities that would require authorisation by the responsible heritage resources authority. Activities considered applicable to the proposed project include the following: “(a) The construction of a road, wall, powerline, pipeline, canal or other similar form of linear development or barrier exceeding 300 m in length; (c) any development or other activity which will change the character of a site; and (i) exceeding 5000 m² in extent.” The NHRA requires that a person intending to undertake such an activity must notify the relevant national and provincial heritage authorities at the earliest stages of initiating such a development. The relevant heritage authority would then in turn, notify the person whether a Heritage Impact Assessment Report should be submitted. According to Section 38(8) of the NHRA, a separate report would not be necessary if an evaluation of the impact of such development on heritage resources is required in terms of the Environment Conservation Act, 1989 (No. 73 of 1989) (ECA) (now replaced by NEMA) or any other applicable legislation. The decision-making authority must ensure that the heritage evaluation fulfils the requirements of the NHRA and take into account any comments and recommendations made by the relevant heritage resources authority. As such, a Heritage Impact Assessment (HIA) will form part of this EIA process. In South Africa, the law is directed towards the protection of human made heritage, although places and objects of scientific importance are covered. The NHRA also protects intangible heritage such as traditional activities, oral histories and places where significant events happened. Generally protected heritage, which must be considered in any heritage assessment, includes: Any place of cultural significance (described below); Buildings and structures (greater than 60 years of age); Archaeological sites (greater than 100 years of age); Palaeontological sites and specimens; Shipwrecks and aircraft wrecks; and Graves and grave yards. Section 3(3) of the NHRA defines the cultural significance of a place or objects with regard to the following criteria: (a) Its importance in the community or pattern of South Africa’s history; (b) Its possession of uncommon, rare or endangered aspects of South Africa’s natural or cultural heritage; (c) Its potential to yield information that will contribute to an understanding of South Africa’s natural or cultural heritage; (d) Its importance in demonstrating the principal characteristics of a particular class of South Africa’s natural or cultural places or objects; (e) Its importance in exhibiting particular aesthetic characteristics valued by a community or cultural group; (f) Its importance in demonstrating a high degree of creative or technical achievement at a particular period; (g) Its strong or special association with a particular community or cultural group for social cultural or spiritual reasons; (h) Its strong or special association with the life or work of a person, group or organisation of importance in the history of South Africa; and (I) sites of significance relating to the history of slavery in South Africa. While not specifically mentioned in the NHRA, Scenic Routes are recognised as a category of heritage resources which requires grading as the Act protects area of aesthetic significance (clause “e” above). During the Scoping Phase of this process, the heritage impact assessment will be submitted to the SAHRA for comment.
5.3 Subdivision of Agricultural Land Act, 1970 (Act No. 70 of 1970) In terms of the Subdivision of Agricultural Land Act, 1970, any application for change of land use must be approved by the Minister of Agriculture.
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5.4 Conservation of Agricultural Resources, 1983 (Act No. 43 of 1983) The Conservation of Agricultural Resources Act (CARA), 1983 states that no degradation of natural land is permitted. The Act requires the protection of land against soil erosion and the prevention of water logging and salinization of soils by means of suitable soil conservation works to be constructed and maintained. The utilisation of marshes, water sponges and watercourses are also addressed.
5.5 The Environment Conservation Act, 1989 (Act No.73 of 1989), the National Noise Control Regulations: GN R154 of 1992 The Environment Conservation Act, 1989 (ECA) allows the Minister of Environmental Affairs and Tourism (“now the Minister of Environmental Affairs”) to make regulations regarding noise, amongst other concerns. The Minister has made noise control regulations under the ECA. In terms of section 25 of the ECA, the national noise-control regulations (NCR) were promulgated (GN R154 in Government Gazette No. 13717 dated 10 January 1992). The NCRs were revised under Government Notice Number R. 55 of 14 January 1994 to make it obligatory for all authorities to apply the regulations. Subsequently, in terms of Schedule 5 of the Constitution of South Africa of 1996 legislative responsibility for administering the NCR was devolved to provincial and local authorities. These regulations define "disturbing noise” as: “Noise level which exceeds the zone sound level or, if no zone sound level has been designated, a noise level which exceeds the ambient sound level at the same measuring point by 7 dBA or more”. These Regulations prohibit anyone from causing a disturbing noise.
5.6 National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) Section 34 of the Air Quality Act, 2004 (AQA) makes provision for: (1) The Minister to prescribe essential national noise standards - (a)For the control of noise, either in general or by specified machinery or activities or in specified places or areas; or (b)For determining – (i) a definition of noise; and (ii) The maximum levels of noise. (2) When controlling noise the provincial and local spheres of government are bound by any prescribed national standards. This section of the Act is in force, but no such standards have yet been promulgated. An atmospheric emission license issued in terms of Section 22 may contain conditions in respect of noise. This however will not be relevant to the WEF.
5.7 National Water Act, 1998 (Act No. 36 of 1998) The National Water Act, 1998 (NWA) provides for constitutional requirements including pollution prevention, ecological and resource conservation and sustainable utilisation. In terms of this Act, all water resources are the property of the State. A water resource includes any watercourse, surface water, estuary or aquifer, and, where relevant, its bed and banks. A watercourse is interpreted as a river or spring; a natural channel in which water flows regularly or intermittently; a wetland lake or dam into which or from which water flows; and any collection of water that the Minister may declare to be a watercourse. Relevant water uses for the proposed construction of WEF, which will require access roads over watercourses and drainage channels, in terms of Section 21 of the Act include, but are not limited to, the following: Section 21(c): Impeding or diverting the flow of water in a watercourse; and Section 21(i): Altering the bed, banks, course or characteristics of a watercourse. GN 1199 of 18 December 2009 grants general authorisation for the above water uses based on certain conditions. It is also stipulates that these water uses must be registered with the responsible authority. Pollution of river water is a contravention of the NWA. Chapter 3, Part 4 of the NWA deals with pollution prevention and in particular the situation where pollution of a water resource occurs or might occur as a
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result of activities on land. The person who owns, controls, occupies or uses the land in question is responsible for taking measures to prevent pollution of water resources. Chapter 3, Part 5 of the NWA deals with pollution of water resources following an emergency incident, such as an accident involving the spilling of a harmful substance that finds or may find its way into a water resource. The responsibility for remedying the situation rests with the person responsible for the incident or the substance involved. The EIA phase shall determine whether any general authorisations or Water Use License Applications (WULAs) will be required in terms of the NWA for the proposed development.
5.8 National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004) – Threatened or Protected Species List Amendments to the Threatened or Protected Species (TOPS) list were published on 31 March 2015 in Government Gazette No. 38600 and Notice 256 of 2015. Certain species that occur on the site may be threatened or protected.
5.9 The Nature and Environmental Conservation Ordinance No. 19 of 1974 This was developed to protect both animal and plant species within the various provinces of the country which warrant protection. These may be species which are under threat or which are already considered to be endangered and species are listed in the relevant documents. The provincial environmental authorities are responsible for the issuing of permits in terms of this legislation.
5.10 Additional Relevant Legislation The applicant must also comply with the provisions of other relevant national legislation. Additional relevant legislation that has informed the scope and content of this Final Scoping Report includes the following: Constitution of the Republic of South Africa, 1996 (Act No. 108, 1996); Aviation Act, 1962 (Act No. 74, 1962); National Environmental Management: Waste Act, 2008 (Act No. 59, 2008); National Forest Act, 1998 (Act No. 84, 1998); National Environmental Management: Protected Areas Act, 2003(Act No. 57, 2003); National Roads Act, 1998 (Act No. 7, 1998) Occupational Health and Safety Act, 1993 (Act No. 85 of 1993); National Veld and Forest Fire Bill of 10 July 1998; Fertiliser, Farm Feeds, Agricultural Remedies and Stock Remedies Act, 1947 (Act No. 36 of 1947; Astronomy Geographic Advantage Act, 2007 (Act No. 21 of 2007) Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002); and Independent Communications Authority of South Africa Act, 2000 (Act No. 13 of 2000; as amended). 5.11 Conventions and Treaties
5.11.1 The Paris Agreement (2016) South Africa is one of 195 countries that are signatory to The Paris Agreement. The Paris Agreement is a legally binding instrument within the United Nations Framework Convention on Climate Change (UNFCCC) that provides guidance for action on climate change, focusing on sustainable development and poverty eradication. It sets the goal of preventing increase in global average temperature to below 2 degrees Celsius and pursuing efforts to limit global temperature increase to 1.5 degrees Celsius. Minister of Environmental Affairs Ms Edna Molewa signed the Paris Agreement on Climate Change on behalf of South Africa on 22 April 2016.14 Updates on South Africa’s progress to meet targets of the Paris Agreement may be viewed at the following link: https://climateactiontracker.org/countries/south-africa/ (accessed on 27 May 2018). An extract of this Progress Summary is provided below:
14https://www.environment.gov.za/mediarelease/southafrica_ratifies_parisagreement (accessed on 27 May 2018).
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“South Africa’s Nationally Determined Contribution (NDC) contains a target to limit greenhouse gas (GHG) emissions including land use, land use change and forestry (LULUCF) to between 398 and 614 MtCO2e over the period 2025–2030. This target is equivalent to a 19–82% increase on 1990 levels excl. LULUCF. South Africa’s NDC is consistent with its pledge under the Copenhagen Accord, which proposed emissions reductions below business-as-usual (BAU) levels, incl. LULUCF, by 34% in 2020 and 42% in 2025. This represents a 19–73% increase in emissions excl. LULUCF in 2020 and a 19–82% increase in 2025 on 1990 levels, excl. LULUCF. One of South Africa’s key policies to reduce emissions is the Integrated Resource Electricity Plan (IRP) 2010–2030, which sets a renewable capacity target of total 17.8 GW for 2030. However, the plan foresees coal generation growing at a similar rate. By 2030, the IRP base case expects South Africa to have 21% of electricity generation from renewable energy and 48% from coal.” The proposed Juno WEF fits the emission reduction targets of the Paris Agreement and its aim of sustainable development.
5.11.2 The Convention on Biological Diversity (CBD) (1993) This is a multilateral treaty for the international conservation of biodiversity, the sustainable use of its components and fair and equitable sharing of benefits arising from natural resources. Signatories have the sovereign right to exploit their own resources pursuant to their own environmental policies, and the responsibility to ensure that activities within their jurisdiction or control do not cause damage to the environment of other States or of areas beyond the limits of national jurisdiction. The convention prescribes that signatories identify components of biological diversity important for conservation and monitor these components in light of any activities that have been identified which are likely to have adverse impacts on biodiversity. The CBD is based on the precautionary principle which states that where there is a threat of significant reduction or loss of biological diversity, lack of full scientific certainty should not be used as a reason for postponing measures to avoid or minimise such a threat and that in the absence of scientific consensus the burden of proof that the action or policy is not harmful falls on those proposing or taking the action.
5.11.3 The Convention on the Conservation of Migratory Species of Wild Animals (CMS or Bonn Convention) (1983) An intergovernmental treaty, concluded under the sponsorship of the United Nations Environment Programme, concerned with the conservation of wildlife and habitats on a global scale. The fundamental principles listed in Article II of this treaty state that signatories acknowledge the importance of migratory species being conserved and agree to take action to this end "whenever possible and appropriate", "paying special attention to migratory species the conservation status of which is unfavourable and taking individually or in cooperation appropriate and necessary steps to conserve such species and their habitat”.
5.11.4 The Agreement on the Conservation of African-Eurasian Migratory Waterbirds (AEWA) (1999) An intergovernmental treaty developed under the framework of the Convention on Migratory Species (CMS), concerned the coordinated conservation and management of migratory waterbirds throughout their entire migratory range. Signatories of the Agreement have expressed their commitment to work towards the conservation and sustainable management of migratory waterbirds, paying special attention to endangered species as well as to those with an unfavourable conservation status. The assessment of the ecology and identification of sites and habitats for migratory waterbirds is required to coordinate efforts that ensure that networks of suitable habitats is maintained and investigate problems likely posed by human activities.
5.12 Policies and Guidelines
5.12.1 Environmental Impact Assessment Guidelines Relevant guidelines and policies as applicable to the management of the EIA process and to this application have also been taken into account, as indicated below: Integrated Environmental Management (IEM) Guideline Series (Series 2): Scoping in the EIA process (2002); IEM Guideline Series (Series 3): Stakeholder engagement (2002); IEM Guideline Series (Series 4): Specialist studies (2002); IEM Guideline Series (Series 5): Impact Significance (2002);
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IEM Guideline Series (Guideline 5): Companion to the EIA Regulations 2010 (October 2012); IEM Guideline Series (Series 7): Cumulative Effects Assessment (2002); IEM Guideline Series (Guideline 7): Public Participation in the EIA process (October 2012); IEM Guideline Series (Series 7): Alternatives in the EIA process (2002); IEM Guideline Series (Guideline 9): Draft guideline on need and desirability in terms of the EIA Regulations 2010 (October 2012); DEA (2017) Guideline on Need and Desirability, Department of Environmental Affairs (DEA) Pretoria, South Africa; IEM Guideline Series (Series 12): Environmental Management Plans (EMP) (2002); and IEM Guideline Series (Series 15): Environmental impact reporting (2002). 5.12.2 Noise Standards
5.12.2.1 National Four South African Bureau of Standards (SABS) scientific standards are considered relevant to noises from a Wind Energy Facility. They are: SANS 10103:2008. ‘The measurement and rating of environmental noise with respect to annoyance and to speech communication’; SANS 10210:2004. ‘Calculating and predicting road traffic noise’; SANS 10328:2008. ‘Methods for environmental noise impact assessments’; and SANS 10357:2004. ‘The calculation of sound propagation by the Concave method’. The relevant standards use the equivalent continuous rating level as a basis for determining what is acceptable. The levels may take single event noise into account, but single event noise by itself does not determine whether noise levels are acceptable for land use purposes. The recommendations that the standards make are likely to inform decisions by authorities, but non-compliance with the standards will not necessarily render an activity unlawful per se.
5.12.2.2 International There exists a number of international guidelines and the three described below are selected as they are used by different countries in the subject of environmental noise management, with the last two documents specifically focussing on the noises associated by wind energy facilities. Due to the lack of local regulations specifically relevant to wind energy facilities, these guidelines will also be considered during the determination of the significance of noise impacts.
Guidelines for Community Noise (Word Health Organisation, 1999) The World Health Organization’s (WHO) document on the Guidelines for Community Noise is the outcome of the WHO- expert task force meeting held in London, United Kingdom, in April 1999. It is based on the document entitled “Community Noise” that was prepared for the World Health Organization and published in 1995 by the Stockholm University and Karolinska Institute. The scope of the WHO's effort to derive guidelines for community noise is to consolidate actual scientific knowledge on the health impacts of community noise and to provide guidance to environmental health authorities and professionals trying to protect people from the harmful effects of noise in non-industrial environments. Guidance on the health effects of noise exposure of the population has already been given in an early publication of the series of Environmental Health Criteria. The health risk to humans from exposure to environmental noise was evaluated and guidelines values derived. The issue of noise control and health protection was briefly addressed. The document uses the LAeq and LA,max descriptors to define noise levels with the instrument likely using the “Fast”-time weighting. This document was important in the development of the SANS 10103 standard.
The Assessment and Rating of Noise from Wind Farms (1997) This report describes the findings of a Working Group on Wind Turbine Noise, facilitated by the United Kingdom Department of Trade and Industry. It was developed as an Energy Technology Support Unit15 (ETSU) project. The aim of the project was to provide information and advice to developers and planners
15 ETSU was set up in 1974 as an agency by the United Kingdom Atomic Energy Authority to manage research programmes on renewable energy and energy conservation. The majority of projects managed by ETSU were carried out by external organizations in academia and industry. In 1996, ETSU became part of AEA Technology plc which was separated from the UKAEA by privatisation.
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on noise from wind turbines. The report represents the consensus view of a number of experts (experienced in assessing and controlling the environmental impact of noise from wind farms). Their findings can be summarised as follows: 1. Absolute noise limits applied at all wind speeds are not suited to wind farms; limits set relative to the background noise (including wind) are more appropriate. 2. LA90,10mins is a much more accurate descriptor when monitoring ambient and turbine noise levels. 3. The effects of other wind turbines in a given area should be added to the effect of any proposed wind energy facility, to calculate the cumulative effect. 4. Noise from a wind energy facility should be restricted to no more than 5 dBA above the current ambient noise level at a NSD. Ambient noise levels is measured on-site in terms of the LA90,10min descriptor for a period sufficiently long enough for a set period. 5. Wind farms should be limited to within the range of 35 dBA to 40 dBA (day-time) in a low noise environment. A fixed limit of 43 dBA should be implemented during all night time noise environments. This should increase to 45 dBA (day and night) if the NSD has financial investments in the wind energy facility. 6. A penalty system should be implemented for wind turbine/s that operates with a tonal characteristic. This is likely the guideline used in the most international countries to estimate the potential noise impact stemming from the operation of a wind energy facility. It also recommends an improved methodology (compared to a fixed upper noise level) on determining ambient sound levels in periods of higher wind speeds, critical for the development of a wind energy facility. Because of its international importance, the methodologies used in the ETSU R97 document will be recommended in this Scoping Report for implementation during the Environmental Noise Impact Assessment phase should projected noise levels (from the proposed WEF at PSRs) exceed the zone sound levels as recommended by SANS 10103:2008.
The document uses the LAeq,f and LA90 descriptors to define noise levels using the “Fast”-time weighting. Noise Guidelines for Wind Farms (MoE, 2008)16 This document establishes the sound level limits for land-based wind power generation facilities and describes the information required for noise assessments and submissions under the Environmental Assessment Act and the Environmental Protection Act, Canada (Table 5.2). The document defines: Sound Level Limits for different areas (similar to rural and urban areas), defining limits for different wind speeds at 10 m height; and The Noise Assessment Report, including: Information that must be part of the report; Full description of noise sources; Adjustments, such as due to the wind speed profile (wind shear); The identification and defining of potential sensitive receptors; Prediction methods to be used (ISO 9613-2); Cumulative impact assessment requirements; It also defines specific model input parameters; Methods on how the results must be presented; and Assessment of Compliance (defining magnitude of noise levels). Table 5.2: Summary of Sound Level Limits for Wind Farms (MoE) Wind speed (m/s) at 10 m height 4 5 6 7 8 9 10
Wind Turbine Sound Level Limits, Class 3 40 40 40 43 45 49 51 Area, dBA Wind Turbine Sound Level Limits, Class 1 & 45 45 45 45 45 49 51 2 Areas, dBA
The document used the LAeq,1h noise descriptor to define noise levels. It is not clear whether the instrument must be set to the “Fast” or “Impulse” time weighing setting, but, as the “Fast” setting is used in most international countries it is assumed that the instrument will be set to the “Fast” setting.
16 Noise Guidelines for Wind Farms Interpretation for Applying MOE NPC Publications to Wind Power Generation Facilities Ministry of the Environment, Ontario, October 2008.
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It should be noted that these Sound Level Limits are included for the reader to illustrate the criteria used internationally. Due to the lack of local regulations specifically relevant to wind energy facilities this criteria will also be considered during the determination of the significance of the noise impact.
The Equator Principles (EPs) III, 2013 The principles applicable to the project are likely to include: Principle 2: Environmental and Social Assessment; Principle 3: Applicable Environmental and Social Standards; Principle 4: Environmental and Social Management System and Equator Principles Action Plan; Principle 5: Stakeholder Engagement; Principle 6: Grievance Mechanism; Principle 7: Independent Review ; Principle 8: Covenants; Principle 9: Independent Monitoring and Reporting; and Principle 10: Reporting and Transparency. These principles, among various requirements, include a requirement for an assessment process and an Environmental and Social Management Plan (ESMP) to be prepared by the client to address issues raised in the assessment process and incorporate actions required to comply with the applicable standards, and the appointment of an independent environmental expert to verify monitoring information.
5.12.3 South African Wind Energy Facility Guidelines The following guidelines are relevant to the proposed WEF and the potential impacts they may have on bats/avifauna and habitat that support bats/avifauna: South African Good Practise Guidelines for Surveying Bats in Wind Energy Facility Developments – Pre-Construction (2016); South African Good Practise Guidelines for Operational Monitoring for Bats at Wind Energy Facilities (2014); and Best Practice Guidelines for Avian Monitoring and Impact Mitigation at Proposed Wind Energy Development Sites in Southern Africa. BirdLife South Africa/Endangered Wildlife Trust (2015).
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6 ASSESSMENT OF ALTERNATIVES Alternatives are different means of meeting the general purpose and need of a proposed development and may include alternative sites, alternative layouts or designs, alternative technologies and the “no development” or “no go” alternative. This section describes alternatives in relation to the proposed development. Table 6.2 and Table 6.2 provide a summary of this assessment. The EIA Regulations indicate that alternatives that are considered in an assessment process should be reasonable and feasible, and that I&APs should be provided with an opportunity to provide inputs into the process of formulating alternatives. The assessment of alternatives should, as a minimum, include the following: The consideration of the no-development or “no-go option” alternative as a baseline scenario; A comparison of reasonable and feasible selected alternatives; and The provision of reasons for the elimination of an alternative. 6.1 The No Development Scenario or “No-Go Option” This scenario assumes that the proposed development does not proceed. It is equivalent to the future baseline scenario in the absence of the proposed development. Relative to the proposed development, the implications of this scenario include: The land-use remains agricultural, with no further benefits derived from the implementation of a complementary land use; There is no change to the current landscape or environmental baseline; No additional electricity will be generated on-site or supplied through means of renewable energy resources. This would have negative implications for the South African government in achieving its proposed renewable energy target, given the need for increased generation; There is no opportunity for additional employment (permanent or temporary) in the local area where job creation is identified as a key priority; and The national and local economic benefits associated with the proposed project’s REIPPPP commitments and broader benefits would not be realised. The purpose of the proposed development is to generate renewable electricity and export this to the national grid. Other socio-economic and environmental benefits will result from the proposed development such as:
Reduced air pollution emissions - burning fossil fuels generates CO2 emissions which contributes to global warming. Emissions of sulphurous and nitrous oxides are produced which are hazardous to human health and impact on ecosystem stability; Water resource saving – conventional coal-fired power stations use large quantities of water during their cooling processes. WEFs require limited amounts of water during construction and a minimal amount of water during operation. As a water stressed country, South Africa needs to be conserving such resources wherever possible; Improved energy security – renewables can be deployed in a decentralised way close to consumers, improving grid strength while reducing expensive transmission and distribution losses. Renewable energy projects contribute to a diverse energy portfolio; Exploit significant natural renewable energy resources – biomass, solar and wind resources remain largely unexploited; Sustainable energy solutions – the uptake of renewable energy technology addresses the country’s energy needs, generation of electricity to meet growing demands in a manner which is sustainable for future generations; and Employment creation and other local economic benefits associated with support for a new industry in the South African economy. The ‘No Development’ alternative would not assist the government in addressing climate change, energy security and economic development. Implementing this option would also not allow for any beneficial socio-economic and environmental impacts as outlined above. Addressing climate change is one of the benefits associated with the implementation of this proposed development. Climate change is widely considered by environmental professionals as one of the single largest threats to the environment on a local, national and global scale. Based on the above, the ‘No Development’ alternative is not a preferred alternative.
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6.2 Site Selection From the outset of the proposed development, AMDA advanced a number of environmental and technical criteria when considering the location of a potential wind facility including: Proximity to residential areas; Proximity to environmentally (social and biophysical environments) and heritage sensitive areas (in consultation with appropriate specialists); Potential impacts on fauna and flora (in consultation with appropriate specialists); Potential visual impact; Potential impact on aviation; Potential wind resource; Presence of obstacles on the site such as rivers, dams, roads, existing gridlines and current land use; Need for grid stabilisation in the area; Need for rural development through job creation in the area; Accessibility of the area as a result of topography; Grid connection options - is connection affordable and in national interest; Willingness of land owners to participate; and Possibility to support land reform objectives.
Publicly available data is obtained from sources such as the Endangered Wildlife Trust (EWT), Cape Nature, Birdlife SA, SANBI, local wildlife groups and other publicly available georeferenced environmental data of South Africa. At this stage of a development initial consultation with key statutory and non- statutory organisations such as Birdlife SA, EWT, SANBI and Provincial/National Department of Environmental Affairs may be completed. Only if no initial, high level issues are identified, will projects proceed to the next stage. After considering the above criteria, specific land portions were identified as being potentially suitable for the development of a 140 MW wind energy facility (WEF). Given the large number of land parcels in the area already secured under option agreement by other developers (including the environmentally approved Inca Vredendal Wind Energy Facility located immediately west of the site) as well as landowners in the area willing to host a potential wind energy facility, the number of available land parcels suitable for development were quickly reduced. Remaining Extent of Farm De Boom No. 273 was subsequently decided upon as the ‘Preferred Site’ for development in the area. A met mast was subsequently installed on site and has confirmed the expected wind resource. A fatal flaws study (conducted by Savannah Environmental (Pty) Ltd in September 2016) and bird and bat monitoring (respectively conducted by Birds and Bats Unlimited and BioInsight) have also since been undertaken. On the basis of these results, a decision was taken by AMDA to proceed to Full Feasibility, which includes the Scoping and EIA process. The aim of the Full Feasibility phase is to address the project at a more detailed level, so as to advance the decision on if the project should proceed, and if so, what are the limitation and constraints to development. This includes consideration of key commercial, environmental, technical and legal issues. The aim for this stage is to inform the decision that the site can be financed and constructed. Since the developer makes a firm commitment towards the project at this point, this is a very important step in the selection process of project sites and the moment when the project is introduced into the public domain. The EIA is one of the key actions identifying site specific environmental feasibility and constraints at the Full Feasibility stage. The EIA therefore forms an important stage in informing the progression of the project, its design, and facilitates the introduction to the public. In brief, the site selection process is a detailed process of identification and elimination of sites and starts with identifying a potentially viable site through the presence of suitable wind resource. A target area for the development was identified with the intention of developing a feasible and sustainable 140 MW Wind Energy Facility. Key criteria considered in the identification of a target area included suitable wind resource, proximity to a suitable grid connection, compatible land use, land accessibility and key environmental sensitivities. A target area of approximately 960 km2 was identified as a result of this exercise. The target area extends from the Olifants River in the north to 50km south and from 2km inland from the coastline in the west to the Olifants River in the east. Site specific investigation was thereafter undertaken within the target area to identify a Preferred Site. On a site-specific level, key selection factors included wind resource, land availability, environmental and social sensitivities, distance to the national grid, site accessibility, topography, current land use and landowner willingness were all considered in the determination of the Preferred Site.
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The Preferred Site extends over a single land portion: The Remaining Extent of Farm De Boom No. 273 (proposed Juno WEF site). An outline of the site selection process specific to the local target area is provided in Table 6.1 below. Based upon the analysis as summarised above and in Table 6.1 Alternatives Table below, the proposed Juno WEF site is the Preferred Site and no other site alternatives will be considered in the EIA Phase.
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Table 6.1: Alternatives Table for the Proposed Juno WEF Suitability of Area Suitability of Area Suitability of Area East Suitability of Area Factor Suitability of the Preferred Site North of Preferred West of Preferred of Preferred Site South of Preferred Site Site Site
The site is a single land parcel that Limited due to existing Limited due to land owner offers suitable buildable area for a development activity, unwillingness and land Land full 140MW facility. Land is currently under including the Limited due to already signed under Availability land claim. environmentally approved proximity to coastline. The landowner has signed consents option agreement by other Inca Vredendal Wind for the undertaking of the EIA developers. process. Energy Facility.
Transformed land Combination of Transformed land currently used for currently used for low Combination of livestock Combination of livestock livestock farming, Land Use low density livestock farming. density livestock farming and crop farming. farming and crop farming. protected areas and farming. residential.
Although the site does contain Sensitivities include environmental features (e.g. High occurrence of high proximity to Olifants Sandlaagte palaeochannel) that sensitivity Sandveld High sensitivity River as well as large Key sensitivities include Environmental have to be avoided due to high Fynbos east of the site as considering proximity sections of the land large areas of Sandveld Sensitivity environmental sensitivity, suitable well as dune systems to coastline and earmarked for National Fynbos. area is still available, following classified as a Critical residential areas. Protected Area these exclusions, to develop a 140 Biodiversity Area. Expansion. MW facility.
Above average wind speed Wind speed Average on the basis of Average on the basis of Average on the basis of Average on the basis confirmed through over two years levels satellite data. satellite data. satellite data. of satellite data. of onsite wind monitoring.
Material disadvantage to The proposed Juno WEF is located No material advantage Slight advantage to developing south of the Material disadvantage approximately 16 km from the to hosting a potential developing east of Preferred Site due to an to developing west of Distance to existing Juno substation. This wind energy facility at Preferred Site due to a extended grid connection the Preferred Site due grid distance is feasible in terms of the this location on the reduced grid connection distance that could to an extended grid economics of the proposed facility basis of distance to grid. distance. potentially render the connection distance. project unfeasible.
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Suitability of Area Suitability of Area Suitability of Area East Suitability of Area Factor Suitability of the Preferred Site North of Preferred West of Preferred of Preferred Site South of Preferred Site Site Site
Site Accessible from R362 Accessible from R362 Accessible from R362 Accessible from R362 Accessible from R362 Accessibility
Topography is Topography is Topography is Topography is Topography at the proposed area is characterised by flat characterised by flat plains characterised by flat plains characterised by flat Topography characterised by flat plains with plains with occasional with occasional gentle with occasional gentle plains with occasional occasional gentle undulations. gentle undulations. undulations. undulations. gentle undulations.
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6.3 Design Evolution Alternatives Following the selection of a suitable site, consideration is given to the design of the WEF and grid connection within that site. It is important that wind turbines are sited in the optimum position to maximise the wind energy yield whilst minimising environmental impacts as far as possible. Information collated during the scoping phase will be used to inform the design of the WEF progressively. Best practice advises that the EIA should be an iterative process rather than a post design environmental appraisal. In this way, the findings of the technical environmental studies will be used to inform the design of a development. This approach will be adopted with respect to this proposed development, and where potentially significant impacts are identified, efforts will be made to avoid these through evolving the design of the proposed development. This will be referred to as mitigation to be embedded in the layout and design, or ‘embedded mitigation’. A preliminary layout was produced showing suggested locations of wind farm turbines on the site. This layout will be adjusted, based on the initial scoping assessment and specialists’ findings. This adjusted layout will be called the ‘preferred layout’ and will be assessed in further detail during the EIA Phase.
6.4 Technology Alternatives Additional renewable energy technologies include hydro-electric power, photovoltaic solar or concentrated solar power. The site itself has no resource for hydro-electricity. Solar electricity generation would require a much greater infrastructure footprint to generate the equivalent energy of the proposed WEF. Based on the site’s physical characteristics and existing land uses, the renewable energy technology best suited to the site, taking into account the potential environmental impacts, is a WEF, however the specific design at the site should be informed by the EIA process. Various wind turbine designs and layouts will be considered for the site in order to maximise the electricity generation capacity and efficiency, whilst taking into account environmental constraints.
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Table 6.2: Assessed Alternatives Summary Alternative Alternative description Advantages Disadvantages Result Type
No The proposed development No change in current landscape or Land use remains low agricultural, without Not Development does not proceed environmental baseline benefits from complimentary land use reasonable No risk of negative environmental and social No additional electricity will be generated impacts through renewable resources No opportunity for additional employment (permanent or temporary) in an area where job creation is identified as a key priority No socio-economic benefits for the community associated with the establishment of a renewable energy facility The government will not be assisted in addressing climate change, energy security and economic development Preferred The Proposed Development Good wind Potential visual sensitive receptors Reasonable Location Site Accessible for wind turbine delivery Potential ecological sensitivities and feasible Proximity to Eskom grid Surrounding area not densely populated Site is transformed agricultural land with current land use grazing Landowner consent
Technology Wind Energy Facility Emits no CO2 and has no fuel costs WEFs pose collision risk to birds and bats Feasible and Can share land use with other activities Potential visual impact and impact on sense of reasonable Small footprint (little habitat loss) compared to place other means of equivalent electricity Dependent on availability of wind generation Contributes to government renewable energy goals Technology Photo-voltaic or Solar PV poses less risk to birds and bats Solar power has much larger footprint (habitat Not concentrated solar loss) reasonable Technology Concentrated Solar Power No collision risk to bats CSP poses incineration and collision risk to birds Not and loss of foraging habitat reasonable
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Alternative Alternative description Advantages Disadvantages Result Type
Technology Hydro-electric Almost no emissions and no fuel costs No hydro-electric resources in area Not feasible Large-scale and stable electricity generation Significant impact on the landscape and river No risk of collision for birds & bats systems Technology Biomass Carbon neutral over time More expensive than other forms of energy Not feasible Given the low agricultural potential of the area, biomass supply difficult to secure at present. Technology Coal-fired power plant Cheapest form of energy and abundant Emits high levels of CO2, major pollutant and Not resource contributes to climate change reasonable Stable and long-term electricity generation Coal mining impacts significantly on the environment Technology Nuclear power Low carbon footprint with small amounts of Most expensive form of energy; requires major Not raw material investments reasonable or Safety concerns (highly radioactive raw and feasible waste material) Radioactive toxic waste product Very long timelines until energy generation can start Design Preferred Layout Maximises wind Potential residual negative impacts Reasonable 140 MW - 59 turbines with a Minimises negative impacts and feasible generation capacity between Will be determined during EIA Phase following 2.6 or 3.4 MW and a rotor specialist recommendations diameter of up to 132 m, a tip height of up to 180 m and blade length of up to 64.5 m.
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7 GEOLOGY, SOILS AND AGRICULTURAL POTENTIAL ASSESSMENT
7.1 Methodology A site visit was carried out to do a number of spot checks to assess the general accuracy of the existing information. A total of 39 soil observations were made across the study area. The area is dominated by red soil of the Hutton form, with varying depth and underlying material. The list of soil observation sites is given in Table 7.1 and illustrated in Figure 7.1 below.
Figure 7.1. Soil map showing soil observation points.
Furthermore, existing information was obtained from the map of the survey: “A Reconnaissance soil survey of the Olifants River – Vredendal to Van Rhynsdorp” (Rudman et al., 1978) and the land type sheet 3118 Calvinia (Land Type Survey Staff, 2012) which is part of the national Land Type Survey published at 1:250 000 scale. The soils are classified according to the Binomial Soil Classification System for South Africa (MacVicar et al., 1977).
It should be clearly noted that, since the information contained in the Olifants River survey is of a reconnaissance nature, only the general dominance of the soils in the landscape can be given, and not the actual areas of occurrence. Also, other soils that were not identified due to the scale of the survey may also occur.
Table 7.1 - General Soil Descriptions
Map Dominant Sub- Depth Characteristics General Agric. unit soil form dominant (mm) Potential /series soil form /series Hu1 Hu31 Hu30, > 600 Moderately deep to deep, Low Hu40, reddish, fine- to medium- Hu41 grained, non-calcareous to calcareous sandy soils, underlain by dorbank or calcrete. Scattered aeolian sand dunes occur throughout the area
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Hu2 Hu33 Hu31, < 300 Shallow, reddish, fine- to Very low Hu41, medium-grained, non- Hu43, calcareous to calcareous sandy Hu30 soils, underlain by dorbank. Hu3 Hu43 Hu41, < 300 Shallow, reddish, fine- to Very low Hu40, medium-grained, calcareous Hu44 sandy soils, underlain by calcrete. Hu4 Hu30, Hu31 Hu34 > 1200 Deep, reddish, fine-grained, Low mostly active aeolian sand. Oa1 Oa33, Oa36, Du10, 800 - Moderately deep to deep, grey- Med- High Oa37, Oa46, Kd10, 1200 brown to reddish brown, (esp. when irrigated) Oa13, Oa16, Kd11, sandy/loamy, non-calcareous to Oa26, Oa34, Fw40, calcareous alluvial soils Oa14, Oa23 Fw41 underlain by clay or rock. Ms1 Ms10, Gs13 Gs11, < 300 Shallow, reddish-brown, sandy Very low Ms14, topsoil on rock. Ms12 Kd1 Kd21, Pn31, Av31, > 500 Moderately deep, greyish-red to Low-med. Low Kd22 Lo20, yellow, medium- to coarse- We20, grained, sandy soils underlain by Es41, hydromorphic clay or soft Pn32 plinthite. E Eroded soils Hu41, < 300 Steeper, dissected terrain near Very low Hu43 Hu40, river with loss of topsoil and Hu44 other signs of erosion W Waterway Non-perennial streams Low
7.2 Baseline Environment The area consists mainly of shallow to deep, reddish, fine to medium, non-calcareous to calcareous sandy soils of the Hutton (Hu) soil form underlain by dorbank and calcrete in places. Outside the WEF project area, along the routes of the 3 proposed grid connection alternatives, the soil varies from moderately deep to deep Hutton soils underlain by dorbank, clay and rock. Active windblown sand dunes also occur. When vegetation is disturbed, all the soils are susceptible to wind erosion due to the low clay content of the soils, especially the topsoils. Shallow soils of the Mispah (Ms) and Glenrosa (Gs) soil forms occur closer to the Olifants River on the steeper, eroded slopes. Alluvial soils in the valley bottom of the Olifants River consist mainly of moderately deep to deep Oakleaf (Oa), Dundee (Du) and Kroonstad (Kd) soil forms.
A general soil description of the map units is given in Table 7.2 with an agricultural potential rating for dryland cultivation.
Table 7.2: Soil Observations
LATITUDE LONGITUDE OBS. FORM & EFF. DEPTH NO. SERIES DEPTH LIMITING (mm) MAT. -31,74930819 18,26631546 A1 Hu30 1000 -31,75412008 18,27049434 A2 Cv30 900 -31,74583205 18,25755537 A3 Hu30 700 Calcrete -31,74395987 18,26147139 A4 Hu30 900 Calcrete -31,74155661 18,26686263 A5 Hu30 1200 -31,72910579 18,28432381 A6 Hu30 1200 -31,71667644 18,29480588 A7 Hu30 900 -31,71305009 18,30664515 A8 Hu30 1200 -31,72157415 18,31609726 A9 Hu30 600 -31,74730727 18,25325847 A10 Hu30 600 Dorbank -31,73867592 18,27923834 A11 Hu30 1000 Calcrete -31,73706659 18,29228997 A12 Hu30 550 Dorbank -31,73761913 18,30333531 A13 Hu31 1200
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-31,73766204 18,30565274 A14 Hu31 1000 Dorbank -31,73042544 18,31239045 A15 Hu31 1200 -31,72618755 18,31632257 A16 Hu30 1200 -31,71990582 18,31859171 A17 Hu31 900 Dorbank -31,71791025 18,32000792 A18 Hu30 1200 -31,71422490 18,32139194 A19 Hu31 1100 Clay -31,70408615 18,32580149 A20 Hu30 1200 -31,73084923 18,32885921 A21 Hu30 1200 -31,73700750 18,33543599 A22 Hu30 1200 -31,62543842 18,39922965 A23 Hu30 400 Rock -31,63985797 18,41006569 A24 Ms10 150 Rock -31,61349186 18,43737602 A25 Hu30 150 Dorbank -31,66287669 18,38635504 A26 Oa23 250 Dorbank -31,65879973 18,37440848 A27 Hu30 300 Dorbank -31,66904577 18,36317539 A28 Hu30 1200 -31,67399713 18,35781097 A29 Hu33 1100 -31,68268212 18,35814893 A30 Hu31 700 Dorbank -31,68763884 18,35219979 A31 Hu31 600 -31,68854007 18,34952831 A32 Hu30 900 -31,64839813 18,39838743 A33 Hu30 600 -31,64538869 18,40408981 A34 Hu31 500 Stones -31,64307662 18,40631604 A35 Hu30 600 -31,62050852 18,43084753 A36 Hu33 350 Dorbank -31,61918350 18,43014479 A37 Hu31 400 Dorbank -31,61973604 18,41880441 A38 Hu31 500 Dorbank -31,61934980 18,41230810 A39 Hu30 900
7.3 Assumptions and Limitations The suitability of soils for the production of crops in a specific locality depends mainly on the inherent chemical, physical and morphological properties of the soils, combined with prevailing climate and crop requirements. The soil limitations that were noted are mainly:
Restricted soil depth to hardpan dorbank, calcrete, clay or rock. Low clay content of top- and upper subsoils giving rise to low water-holding capacity and increased wind erosion susceptibility. Presence of free carbonates indicating a low degree of leaching, giving rise to high pH values and low trace element status, associated with low levels of natural fertility.
As can be seen from the information contained in Table 7.2 and the above-mentioned limitations, there are virtually no high potential soils in the study area except for the alluvial soils of the Olifants River under irrigation. Due to the prevailing low potential of the soils and climate in the area, backed up by the lack of any agricultural infrastructure evident from remote imagery, it can be assumed that this scale of soil information is sufficient for sensible and reliable decision-making.
The average annual rainfall for this area is around 170 mm, giving rise to a low production potential (rainfall 200 – 300 mm/year, if <20% in summer) (Jacobs, 1999). The very low rainfall in the area means that there is little or no potential for rain-fed arable agriculture in the area. Annual crops such as small grain (wheat and Triticale) were taken into consideration for the agricultural potential rating. Arable production would therefore be very problematic without irrigation.
In general, the soils are suited for extensive grazing at best and the grazing capacity of the area is relatively low, at around 25-30 ha/large stock unit (ARC-ISCW, 2004).
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7.4 Preliminary Assessments
7.4.1 Construction and Operation Phase Impacts Impact Phase: Construction and Operational Phase Impact description: Loss of Agricultural land Extent Duration Intensity Status Significance Probability Confidence Without L L L Negative L L L Mitigation With L L L Negative L L H Mitigation Can the impact be reversed? Yes, very little land will be affected soil can be replaced. Will impact cause irreplaceable No, soil potential in vicinity is low, so no agricultural soils will be loss or resources? affected. Can impact be avoided, Yes managed or mitigated? Mitigation measures: Avoid any areas of cultivation (if any). Impact to be addressed/ No, considered to be insignificant due to very restricted occurrence of further investigated and agricultural soils. assessed in Impact Assessment Phase?
Impact Phase: Construction and Operational Phase Impact description: Increased soil erosion hazard Extent Duration Intensity Status Significance Probability Confidence Without L M M Negative M M H Mitigation With L L L Negative L L H Mitigation Can the impact be reversed? Yes, topsoil coverage can be replaced and affected sites re-vegetated and stabilized. Will impact cause irreplaceable No, soil potential in vicinity is low, so no agricultural soils will be loss or resources? affected. Can impact be avoided, Yes, soil conservation measures should be implemented. managed or mitigated? Mitigation measures: Minimize vegetation removal to smallest possible footprint; Control possible runoff by using soil conservation and soil retention measures, especially on steep slopes; Store any removed topsoil for later use (contains indigenous seeds etc.) and re-vegetate as soon as possible; Once specific infrastructure sites are known, site-specific measures can be devised for implementation and any potentially high risk sites can be identified; Regular monitoring of disturbed area footprint. Impact to be addressed/ No further investigated and assessed in Impact Assessment Phase?
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7.4.2 Cumulative Phase Impacts Impact Phase: Cumulative Phase Impact description: Increased soil erosion if two or more facilities utilize the same terrain (e.g. access roads or other infrastructure) Extent Duration Intensity Status Significance Probability Confidence Without L M M Negative M M H Mitigation With L L L Negative L L H Mitigation Can the impact be reversed? Yes, topsoil coverage can be replaced and affected sites re-vegetated and stabilized. Will impact cause irreplaceable No, soil potential in vicinity is low, so no agricultural soils will be loss or resources? affected. Can impact be avoided, Yes, soil conservation measures should be implemented. managed or mitigated? Mitigation measures: Minimize vegetation removal to smallest possible footprint; Control possible runoff by using soil conservation and soil retention measures, especially on steep slopes; Store any removed topsoil for later use (contains indigenous seeds etc) and re-vegetate as soon as possible; Once specific infrastructure sites are known, site-specific measures can be devised for implementation and any potentially high risk sites can be identified; Regular monitoring of disturbed area footprint. Impact to be addressed/ No further investigated and assessed in Impact Assessment Phase?
7.5 Summary / Conclusion The prevailing potential of the soils for rain-fed cultivation throughout most of the area is low. The lack of any high potential agricultural resources, as well as the nature of the proposed project infrastructure means that, from the point of view of soils, there is no reason why the project should not be authorized. This will, however, be contingent on the mitigation measures as specified in the impacts tables being applied and implemented.
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8 FLORA AND FAUNA (TERRESTRIAL ECOLOGY) ASSESSMENT
8.1 Methodology
8.1.1 Pattern Community and ecosystem level The main vegetation type, its aerial extent and interaction with neighbouring types, soils or topography; Threatened or vulnerable ecosystems (cf. SA vegetation map/National Spatial Biodiversity Assessment, fine-scale systematic conservation plans, etc.).
Species level Species of Conservation Concern (SCC) (giving location if possible using GPS); The viability of an estimated population size of the RDB species that are present (including the degree of confidence in prediction based on availability of information and specialist knowledge, i.e. High=70-100% confident, Medium 40-70% confident, low 0-40% confident); The likelihood of other RDB species, or species of conservation concern, occurring in the vicinity (include degree of confidence).
Fauna Describe and assess the terrestrial fauna present in the area that will be affected by the proposed development; Conduct a faunal assessment that can be integrated into the ecological study; Describe the existing impacts of current land use as they affect the fauna; Clarify species of special concern (SSC) and that are known to be . endemic to the region; . that are considered to be of conservational concern; . that are in commercial trade (CITES listed species); or . are of cultural significance. Provide monitoring requirements as input into the EMPr for faunal related issues.
Other pattern issues Any significant landscape features or rare or important vegetation associations such as seasonal wetlands, alluvium, seeps, quartz patches or salt marshes in the vicinity. The extent of alien plant cover of the site, and whether the infestation is the result of prior soil disturbance such as ploughing or quarrying (alien cover resulting from disturbance is generally more difficult to restore than infestation of undisturbed sites). The condition of the site in terms of current or previous land uses.
8.1.2 Process The key ecological “drivers” of ecosystems on the site and in the vicinity, such as fire. Any mapped spatial component of an ecological process that may occur at the site or in its vicinity (i.e. corridors such as watercourses, upland-lowland gradients, migration routes, coastal linkages or inland-trending dunes, and vegetation boundaries such as edaphic interfaces, upland-lowland interfaces or biome boundaries). Any possible changes in key processes, e.g. increased fire frequency or drainage/artificial recharge of aquatic systems. Furthermore, any further studies that may be required during or after the EIA process will be outlined. All relevant legislation, permits and standards that would apply to the development will be identified. The opportunities and constraints for development will be described and shown graphically on an aerial photograph, satellite image or map delineated at an appropriate level of spatial accuracy.
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8.2 Baseline Environment
8.2.1 Vegetation types According to the 2012 update of the national vegetation map (Mucina & Rutherford 2006), there are three vegetation types within the study area, Namaqualand Strandveld which occupies the majority of the site; some Namaqualand Sand Fynbos in the southeast corner of the site (Figure 8.1) and a narrow strip of Cape Inland Salt Pans associated with the bed of the Sandlaagte River.
Namaqualand Strandveld This occurs in the Northern and Western Cape Provinces from the southern Richtersveld as far south as Donkins Bay. Especially in the north of this unit it penetrates up to 40km inland and approaches the coast only near the river mouths of the Buffels, Swartlintjies, Spoeg, Bitter and Groen Rivers. In the south of the unit it is variably narrow and approaches the coast more closely. It consists of flat to undulating coastal peneplain. The vegetation consists of a low species richness shrubland dominated by a plethora
Figure 8.1 Vegetation Map (Mucina and Ruttherford 2006 and 2012 Powrie Update) of the Juno study area and surrounding area
of erect and creeping succulent shrubs as well as woody shrubs and in wet years annuals are also abundant. It is associated with deep red or yellowish-red Aeolian dunes and deep sand overlying marine sediments and granite gneisses. The area is a combination of Ah, Ae, Af, Ai and Ag land types. Mucina
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and Rutherford list eight endemic species for this vegetation type. About 10% of this vegetation type has been lost mainly to coastal mining for heavy metals and it is not currently listed.
Namaqualand Sand Fynbos There is a narrow strip of mapped Namaqualand Sand Fynbos along the eastern boundary of the study area, which occurs on loose sands and low dunes present in this area. Namaqualand Sand Fynbos is similar to but considered to be a more depauperate form of Leipoldtville Sand Fynbos, lacking most of the special species of the latter. It typically occurs on acid to neutral sands, often on windblown dunes and on the dune slacks. It is distributed in the Northern and Western Cape from the vicinity of the study area to Hondeklipbaai in the north, along the coastal plain. It occurs on Aeolian deep, loose, red sands overlying marine or other sediments. Land types are mainly Ah, Hb and Ai. It is usually a low to medium shrubland, often dominated by restios, with Proteaceae often present, usually in low numbers. Bulbs and annuals may be common, with succulents common only on dune slacks. It is not a fire driven system and often forms mosaics with various Strandveld types, and boundaries can be very diffuse.
Cape Inland Salt Pans This vegetation type is an azonal vegetation type occurs in the Western and to a lesser extent Eastern Cape Provinces, from Jakkalsrivier Valley between Graafwater and Lambert’s Bay, Rocher Pan and other pans near Dwarskersbos (near Velddrif), Soutpan near Yzerfontein, Rondevlei, Paardevlei, Noordhoek (all near Cape Town), salt vleis of the Agulhas Plain, Zoutpan and several other smaller salt pans in the Albertinia region (Zoutpan, Melkhoutfontein, Vogelvlei). The vegetation occurs in small depressions dominated by low succulent scrub composed of creeping chenopods and salt-tolerant herbs and grasses. This vegetation type is considered Least Threatened and 20% is statutorily conserved in the Agulhas and West Coast National Parks as well as in the Soetendalsvlei and Rocherpan Nature Reserves. However, as this ecosystem is associated with hydrological features and plays an important ecological role, it is considered sensitive to disturbance.
8.2.2 Listed and Protected Plant Species The abundance of plant species of conservation concern in the broader area around the Juno site is relatively high. A total of 460 species have been recorded from the half degree 3118C, of which 48 are of conservation concern. Listed species confirmed present at the site include Calobota lotononoides (NT), Wahlenbergia asparagoides (VU), Babiana hirsuta (NT) and Muraltia obovata (VU). There are likely to be additional listed species present at the site as well which were not observed as some species are naturally rare or are only visible at specific times of the year. Although some species such as Muraltia obovata were widespread at the site, others such as Calobota lotononoides and Wahlenbergia asparagoides tended to be more restricted to certain substrates. The area along the Saandlaagte River and the deeper sands south of the river were areas of above average abundance of SCC and is one of the contributing factors to the higher sensitivity of these areas. Overall, there is likely to be some impact on SCC as a result of the development, but no local populations of SCC are likely to be compromised as a result of the development which generally avoids the areas of highest SCC abundance.
8.2.3 Mammals The site lies within the distribution range of approximately 48 terrestrial mammals of which 27 can be confirmed present at the site. Species observed or captured at the site include Steenbok Raphicerus campestris, Common Duiker Sulvicapra grimmia, Aardvark Orycteropus afer, Black-backed Jackal Canis mesomelas, Caracal Caracal caracal, African Wildcat Felis silvestris, Suricate Suricata suricatta, Small Spotted Genet Genetta genetta, Large Grey Mongoose Herpestes ichneumon, Yellow Mongoose Cynictis penicillata, Cape Gray Mongoose Galerella pulverulenta, Striped Polecat Ictonyx striatus, Bat-eared Fox Otocyon megalotis, Cape Fox Vulpes chama, Cape Gerbil Tatera afra, Striped Mouse Rhabdomys pumilio, Karoo Bush Rat Otomys unisulcatus, Porcupine Hystrix africaeaustralis, Cape Molerat Georychus capensis, Cape Dune Mole-rat Bathyergus suillus, Honey Badger Mellivora capensis and Cape Hare Lepus capensis, Western Rock Elephant Shrew Elephantulus rupestris, Hairy-footed Gerbil Gerbilliscus paeba, Namaqua Rock Mouse Aethomys namaquensis Rock Hyrax Procavia capensis and Lesser Dwarf Shrew Suncus varilla. Listed species known from the broader area include the White-tailed Mouse Mystromys albicaudatus (EN) and Van Zyls’ Golden Mole Cryptochloris zyli (EN). The habitat at the site is not considered highly suitable for the White-tailed mouse and it is considered unlikely to be present. Van Zyls’ Golden Mole Cryptochloris zyli, is known from a handful of specimens collected at Compagniesdrift, which is located 40km south of the site as well as a single specimen from Groenriviermond some distance north of the site. Little is known about this species and it is possible that it occurs at the Juno Wind Farm site, but this is not considered to be highly likely as the occurrence of the species appears to be associated with very loose sands that do not occur across the majority of the Juno site. There are however some areas that appear to be
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potentially suitable, especially south of the Sandlaagte River and the dunes associated with the areas of Sand Fynbos in the far eastern corner of the site. The major impact of development on most mammals would be habitat loss equivalent to the footprint of the facility. Particular areas of concern would be the high-lying ground along the southern margin of the site and the paleochannel of the Sandlaagte non-perennial river. Some species may be wary of the turbines or negatively affected by the noise generated and may avoid them to the greater degree. It is however unlikely that the local or regional populations of any species would be compromised by the development and long-term impacts on mammals are likely to be low to moderate after mitigation.
8.2.4 Reptiles The site lies in or near the distribution range of as many as 58 reptile species. Based on distribution maps and habitat requirements, the composition of the reptile fauna is likely to comprise 3 tortoises, 18 snakes, 26 lizards and skinks, 9 geckos and 1 chameleon. Although the majority of the site consists of sandy substrates there are some rocky outcrops along the Sandlaagte River which offer a different habitat to the rest of the site and which are of above average significance for reptiles at the site. This area is however outside of the proposed development footprint and the development would be restricted to the sandy habitats of the site. Gronovi's Dwarf Burrowing Skink is confirmed present at the site and is endemic to the Western Cape, occurring from Doringbaai in the north to Robben Island in the south, and inland to Graafwater. This species is associated with sandy substrates and appears to be fairly common within favourable habitat. The development would result in some habitat loss for this species and other listed species associated with sandy substrates such as Cordylus macropholis. Although it is highly likely that the Speckled Padloper is present at the site, it was not observed and would occur associated with the rocky outcrops in the south of the site which are not within the development footprint. The development would result in the loss of habitat for resident reptiles as well as disrupt the connectivity of the landscape to some extent. As with mammals, the southern boundary of the site with rocky outcrops associated with the non-perennial Sandlaagte River are the most important areas for reptiles at the site. However, as demonstrated by the presence of Gronovi's Dwarf Burrowing Skink, the sandy substrates also harbour species of significance. Overall, impacts of the development on reptiles are likely to be largely of local significance as the development footprint is relatively low and the affected habitat is widely available in the area.
8.2.5 Amphibians Only six species have been recorded from the half degree (3118C) (including the site), although 14 amphibian species are known from the broader area. The vicinity of the Sandlaagte River would be the most important area for frogs as this area may occasionally receive runoff, but in general, the abundance of frogs at the site would be low as there are no freshwater features present at the site that could be used by water-dependent species. Only species which are independent of water are likely to be present, including the Cape Sand Frog Tomopterna delalandii and Namaqua Rain Frog Breviceps namaquensis. Given the paucity of important amphibian habitats at the site and the low likely density of amphibians, a significant impact on frogs is not likely.
8.2.6 Critical Biodiversity Areas and Broad Scale Processes (BSP) In terms of the 2010 NPAES, the majority of the site has been mapped as falling within the Knersvlakte Hantam Focus Area (Figure 8.2). According to the NPAES technical document, NPAES focus areas are “large, intact and unfragmented areas suitable for the creation or expansion of large protected areas.” Development within NPAES Focus Areas is potentially undesirable because this may impact on future conservation options and prevent conservation targets for certain vegetation types being met. It is however important to note that these areas should “not be seen as future boundaries of protected areas, as in many cases only a portion of a particular focus area would be required to meet the protected area targets set in the NPAES”. Although it is not clear why the polygon which includes the site has been selected as a NPAES, this appears to be related to the presence of different vegetation types which are indicative of environmental gradients providing climate change resilience as well as the presence of Leipoldtville Sand Fynbos which is a listed ecosystem. However, the NPAES uses the 2006 VegMap as an input layer and the vegetation map of the study area has since been revised and extent of Leipoldtville Sand Fynbos in the 2012 VegMap revision has been reduced and it is no longer considered to occur within the site. As a result, some of the basis for the NPAES is no longer present and the site is currently mapped as being largely within the Namaqualand Strandveld vegetation type with a small extent of Namaqualand Sand Fynbos along the western margin of the site. Both of these vegetation types have extensive tracts outside of the site and the small extent of these areas within the site is not regionally significant. It is also important to note that the NPAES that includes the site is only 9100ha in extent and does not abut any other focus areas with the result that the potential for disruption of ecological processes is low.
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Figure 8.2 National Protected Areas Expansion Strategy Focus Areas for the Juno site.
The Western Cape BSP for the study area is illustrated below in Figure 8.3 and indicates that the majority of the site falls within an Ecological Support Area. The most important feature of the 2016 BSP compared to the NPAES is the recognition that a large proportion of the site has been mapped as transformed. This agrees within the observations from the site which also identified extensive old croplands within the site. As the NPAES is meant to be based on “large, intact and unfragmented areas” the transformed nature of the site does not appear to have been taken into account within the NPAES as the older land cover information for the site does not map the transformed areas. Consequently, with updated land cover it seems unlikely that the site would still be selected as an NPAES and considering the changes to the VegMap, there seems little basis for maintaining the NPAES status of the site and the Western Cape 2016 BSP is seen as the primary and most accurate conservation status reference for the site, although this is also considered to have some shortcomings which are detailed below.
Under the 2016 Western Cape BSP, the majority of the Juno site lies within an Ecological Support Area, while the eastern corner of the site where the vegetation transitions towards Sand Fynbos and the Sandlaagte River are classified as CBA 1 (8.2). There is also a large extent of the site which is mapped as previously transformed, which is confirmed by the field assessment. In terms of the areas mapped as CBAs, the dunes in the eastern corner of the site are considered more sensitive than the rest of the site and their CBA status is supported by the field assessment. However, the area classified as CBA within the Sandlaagte River is under-mapped and the CBA should be more broadly conceptualised to include the adjacent slopes south of the river with the rocky outcrops as this represents a locally unique and diverse
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habitat for fauna and flora.
Figure 8.3 Critical Biodiversity Areas map for the study area, showing that the majority of the site lies within an ESA 1 with some smaller areas of CBA in the south and east.
In terms of the impact of the development on CBAs, these have been well avoided by the layout and no direct impact on the CBAs would occur. The majority of the footprint is within an ESA and while the ESA would experience some habitat loss, this would not be likely to impact the overall supporting function of the ESA and lead to cascading impacts on adjacent CBAs. As such, the impact of the development on the ecological functioning of the area is likely to be relatively low and no significant disruptions in ecological processes are likely to occur.
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8.2.7 Site Sensitivity Assessment
Figure 8.4 Draft sensitivity map for the study area, showing that the majority of the footprint of the development is in areas of moderate or low sensitivity.
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The draft sensitivity map for the study area is illustrated above in
Figure 8.4. The majority of the site consists of intact Strandveld considered to be of moderate sensitivity. The abundance of plant and animal species in these areas is relatively low and development within these areas would generate moderate to low impacts. A significant proportion of the site has been disturbed for cropping in the past and while some areas have recovered to a significant degree, most areas have not recovered the full complement of species, especially of geophytes and longer-lived species. These areas are considered generally low sensitivity and development within these areas would generate relatively low ecological impacts as they have reduced ecological value and functioning. The Sand Fynbos section in the Far East of the site is considered to be high sensitivity on account to the scarcity of this habitat at the site as well as the greater threat status of the Sand Fynbos compared to the adjacent areas of Strandveld. Habitat loss in this area is considered undesirable and it is not considered suitable for wind farm development. The high-lying ground south of the Sandlaagte River is also considered to be High sensitivity due to the vulnerability of this area to disturbance and the confirmed presence of several plant species of conservation concern. The Sandlaagte River and its immediate environment, including the adjacent rocky outcrops are considered to be Very High sensitivity and should be treated as a no-go area.
8.3 Assumptions and Limitations The current report is based on the results of several site visits as well as a desktop study, which serves to reduce the limitations and assumptions required for the study. The site visits took place in the spring flowering seasons of 2016 and 2017, and while 2017 was a poor season, this is countered by the good conditions during sampling in 2016. As the site has been visited more than once during favourable periods for vegetation sampling, there are few limitations with regards to the vegetation sampling and the species lists obtained are considered reliable and comprehensive. Many remote areas have not been well sampled
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with the result that the species lists derived for the area do not always adequately reflect the actual fauna and flora present at the site. In order to address this potential limitation, and better characterise the faunal community at the site, small mammal trapping using Sherman live traps was conducted over five nights in 2017 within different habitats at the site. Pitfall trapping using eight 20l buckets buried to soil- surface level with 20cm x 8m diversion barriers to increase trapping rate were also used to trap reptiles and amphibians. Ten camera traps were also distributed across the site in October 2017 and retrieved in March 2018 and all images captured were processed and identified to species level. In addition, the consultant has worked extensively in the area, and information from nearby sites is used as and where appropriate.
8.4 Identification of Potential Impacts The development would result in the loss of approximately 80ha of currently intact habitat. This would impact plant species of conservation concern as well as impact fauna directly though mortality and indirectly through habitat loss. The following potential impacts which will be assessed during the EIA phase of the assessment are outlined as follows:
Construction Phase Impacts on vegetation and plant species of conservation concern Direct and indirect faunal impacts Operational Phase Increased soil erosion Increased alien plant invasion Impacts on Fauna Impacts on Critical Biodiversity Areas and NPAES Focus Areas Cumulative impacts Cumulative impacts on habitat loss and broad-scale ecological processes
8.5 Preliminary Assessments The scoping-level assessment of impacts and recommendation of mitigation measures to be applied to reduce impacts is detailed below. It is important to note that this is a Scoping Phase preliminary assessment and the final impact ratings and recommended mitigation actions would be affected by the final development footprint that will be provided by the developer for assessment in the EIA phase. The current assessment highlights the impacts of most concern and the primary mitigation strategies required to reduce impacts to acceptable levels.
8.5.1 Construction Phase Impacts Impact Phase: Construction Phase Impact description: Impacts on vegetation and plant SCC The abundance of plant species of conservation concern at the site is relatively low, with few SCC present across the majority of the site. As a result, there is not a significant risk to the local populations of such species and the major impact is likely to result from the loss of currently intact vegetation more generally. The major impact would result from vegetation clearing for both the turbines with their associated hard stands as well as the access roads between turbines. Extent Duration Intensity Status Significance Probability Confidence Without L H M Negative M H H Mitigation With L H M Negative M M H Mitigation Can the impact be reversed? No. Once transformed, it would be very difficult to restore the previous diversity. Will impact cause irreplaceable No. No species of high conservation concern or listed vegetation types loss or resources? would be affected by the development. Can impact be avoided, Partly. While there is some scope for avoidance of sensitive species and managed or mitigated? habitats, some vegetation loss is an inevitable consequence of development that cannot be avoided.
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Mitigation measures: No development of turbines, roads of other infrastructure within high sensitivity and no-go areas. Preconstruction walk-through of the development footprint to further refine the layout and reduce impacts on SCC through micro-siting of the turbines and access roads. Impact to be addressed/ Yes. This is a certain impact that will be assessed in the EIA phase. further investigated and assessed in Impact Assessment Phase?
Impact Phase: Construction Impact description: Direct and indirect faunal impacts The construction of the development will result in significant habitat loss, noise and disturbance on site. This will lead to direct and indirect disturbance of fauna. Some slow-moving or retiring species such as many reptiles would likely not be able to escape the construction machinery and would be killed. There are also several species present at the site which are vulnerable to poaching and there is a risk that these species may be targeted. This impact would be caused the presence and operation of construction machinery and personnel on the site. Extent Duration Intensity Status Significance Probability Confidence Without L L M Negative M H H Mitigation With L L M Negative M M H Mitigation Yes. Construction phase disturbance will be transient and associated Can the impact be reversed? with the construction phase only. Will impact cause irreplaceable No. No species of high conservation concern are likely to be loss or resources? compromised by the development. Partly. While there is some scope for avoidance of sensitive habitats, Can impact be avoided, some disturbance and habitat loss is an inevitable consequence of managed or mitigated? development that cannot be avoided. Mitigation measures: Avoidance of identified areas of high fauna importance at the design stage. Search and rescue for reptiles and other vulnerable species during construction, before areas are cleared. Limiting access to the site and ensuring that construction staff and machinery remain within the demarcated construction areas during the construction phase. Environmental induction for all staff and contractors on-site.
Impact to be addressed/ further Yes. This is a certain impact that will be assessed in the EIA investigated and assessed in Impact phase. Assessment Phase?
8.5.2 Operational Phase Impacts Impact Phase: Operational Phase Impact description: Increased soil erosion The site has sandy soils that are vulnerable to erosion, especially in the face of the strong winds that the area experiences. Once mobilised, the sands can be very difficult to arrest as the moving sand smothers new vegetation as it goes. The primary impact would likely be from the access roads which may impact on areas where there is already a lot of sand movement or on areas that are currently well-vegetated and where there would be a high risk of wind erosion being initiated. Extent Duration Intensity Status Significance Probability Confidence Without L H M Negative M H H Mitigation With L L L Negative L L H Mitigation Can the impact be reversed? This impact will not occur if appropriate avoidance measures are put in place.
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Will impact cause irreplaceable No. If this impact is addressed, then no significant loss of resources will loss or resources? occur. Can impact be avoided, Yes, with the appropriate mitigation, this impact can be avoided. managed or mitigated? Mitigation measures: Avoiding areas of high wind erosion vulnerability as much as possible. Using net barriers, active rehabilitation and other measures during and after construction to minimise sand movement at the site. Set up a long-term environmental monitoring plan for the site to ensure that erosion is controlled in the long-term. Impact to be addressed/ Yes. This is a highly likely impact that will be assessed in the EIA further investigated and phase. assessed in Impact Assessment Phase?
Impact Phase: Operational Phase Impact description: Increased alien plant invasion There are already several alien species present on the site such as Acacia cyclops and disturbance created during construction would leave the site highly vulnerable to further alien plant invasion, especially along the access roads and other areas which receive additional run-off from the hardened surfaces of the development. Extent Duration Intensity Status Significance Probability Confidence Without L H M Negative M H H Mitigation With L L L Negative L L H Mitigation Can the impact be reversed? This impact will not occur if appropriate avoidance measures are put in place. Will impact cause irreplaceable No. If this impact is addressed, then no significant loss of resources will loss or resources? occur. Can impact be avoided, Yes, with the appropriate mitigation, this impact can be avoided. managed or mitigated? Mitigation measures: Alien management plan to be implemented during the operational phase of the development, which makes provision for regular alien clearing and monitoring. Rehabilitation of disturbed areas that are not regularly used after construction. Impact to be addressed/ Yes. This is a highly likely impact that will be assessed in the EIA further investigated and phase. assessed in Impact Assessment Phase?
Impact Phase: Operational Phase Impact description: Faunal Impacts Operational activities as well as the presence of the turbines and the noise they generate may deter some sensitive fauna from the area. In addition, the access roads may function to fragment the habitat for some fauna, which are either unable to unwilling to traverse open areas. Subterranean species such as Golden Moles and burrowing snakes and skinks are particularly vulnerable to this type of impact as they are unable to traverse the hardened roads or become very exposed to predation when doing so. This is a low-level continuous impact which could have significant cumulative impact on sensitive species. Extent Duration Intensity Status Significance Probability Confidence Without L H M Negative M H H Mitigation With L H L Negative L M H
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Mitigation Can the impact be reversed? No. Habitat loss and disturbance will persist for the lifetime of the facility. The habitat could be partly restored thereafter. Will impact cause irreplaceable No. No species of high conservation concern are likely to be loss or resources? compromised by the development. Can impact be avoided, No. The impacts results from the presence and operation of the facility managed or mitigated? and as such cannot be avoided. Mitigation measures: Open space management plan for the development, which makes provision for favourable management of the facility and the surrounding area for fauna. Limiting access to the site to staff and contractors only. Appropriate design of roads and other infrastructure where appropriate to minimise faunal impacts and allow fauna to pass through or underneath these features. No electrical fencing within 20cm of the ground as tortoises become stuck against such fences and are electrocuted to death. Impact to be addressed/ Yes. This is a highly likely impact that will be assessed in the EIA further investigated and phase. assessed in Impact Assessment Phase?
Impact Phase: Operational Phase Impact description: Impacts on Critical Biodiversity Areas and NPAES Focus Areas Most of the site falls within an NPAES Focus Area, this is not considered to be the most accurate conservation planning information for the site and the development is not considered to have a significant impact on NPAES Focus Areas, especially as the affected Namaqualand Strandveld vegetation type is very widely available along the West Coast and the there are no specific plant communities within the site that are not more widely available in the area. As such impacts on CBAs are seen as the primary impact on conservation planning infrastructure. The majority of the development footprint is located within an area that is classified as an Ecological Support Area. The development will result in direct habitat loss equivalent to about 90ha within the ESA as well as potentially affect broad-scale ecological processes operating in the area. Impact on the ESA would result from the transformation of currently intact habitat as well as the presence and operation of the facility. The layout however makes total avoidance on the CBAs and there would be no direct impact on the CBAs of the area. As a result, the impact of the development on CBAs is likely to be low as some development within the ESA is not likely to impact the overall functioning of the area. Extent Duration Intensity Status Significance Probability Confidence Without L H M Negative M H H Mitigation With L H L Negative L M H Mitigation Can the impact be reversed? No. Habitat loss and disturbance will persist for the lifetime of the facility. The habitat could be partly restored thereafter. Will impact cause irreplaceable No. No species or habitats of high conservation concern are likely to be loss or resources? compromised by the development. Can impact be avoided, Yes. Although the loss of habitat resulting from the development managed or mitigated? cannot be avoided, this can be restricted to areas that are not CBAs. Mitigation measures: Minimise the development footprint as far as possible, which includes locating temporary-use areas such as construction camps and lay-down areas in previously disturbed areas. Avoid impact to restricted and specialised habitats such as pans, wetlands and dune fields. Impact to be addressed/ Yes. This is a highly likely impact that will be assessed in the EIA further investigated and phase. assessed in Impact Assessment Phase?
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8.5.3 Cumulative Phase Impacts Impact Phase: Cumulative Phase Impact description: Cumulative habitat loss and impact on broad-scale ecological processes There are several other renewable energy developments in the wider area and along with the current development, these would contribute to cumulative impacts on habitat loss and fragmentation and negative impact broad-scale ecological processes such as dispersal and climate change resilience. However, the current levels of cumulative impact which can be attributed to wind farm development within the area is still low. Currently, the major impact in the area is from transformation for agriculture, which has had a significant impact on some vegetation in the area. The effected Namaqualand Strandveld vegetation type is however still relatively intact and is not considered to be under threat locally or more broadly. Extent Duration Intensity Status Significance Probability Confidence Without M H M Negative M H H Mitigation With L H L Negative L M H Mitigation Can the impact be reversed? No. Habitat loss and disturbance will persist for the lifetime of the facility. Will impact cause irreplaceable No. No species or habitats of high conservation concern are likely to be loss or resources? compromised by the development. Can impact be avoided, Partly. Sensitive habitats can be avoided, but some contribution to managed or mitigated? cumulative impact in the area is inevitable and cannot be fully avoided or mitigated. Mitigation measures: Avoid impact to restricted and specialised habitats such as dunes or wetlands. Ensure that there are no particular habitats affected within the various renewable energy development sites that are not more widely available or protected elsewhere in the area. Impact to be addressed/ Yes. This is a highly likely impact that will be assessed in the EIA further investigated and phase. assessed in Impact Assessment Phase?
8.6 Conclusions and Recommendations There is little uncertainty with regards to the results of the current study and the conclusions reached are based on actual information collected at the site over two seasons. This information has been used to inform the current layout and ensure that potential impacts associated with the development can be reduced as far as possible at the planning stage. The Juno WEF site is dominated largely by Namaqualand Strandveld except for the small area in the east of the site which is transitional with Sand Fynbos and the area along the Sandlaagte River which has a small amount of riparian vegetation as well as vegetation associated with rocky outcrops. These smaller vegetation units are considered sensitive within the context of the site and not considered suitable for development. The remaining majority area of Namaqualand Strandveld is considered relatively low sensitivity and was observed to have a low abundance of plant species of concern.
In terms of fauna, the site has a relatively diverse mammal and reptile assemblage but a relatively poor amphibian community on account of the absence of any natural standing water sources at the site. Although two listed mammal species may occur at the site, the site is not considered optimal habitat for either and a significant impact on either the White-tailed Mouse Mystromys albicaudatus (EN) and Van Zyls’ Golden Mole Cryptochloris zyli (EN) is considered unlikely. In terms of reptiles, the rocky areas along the Sandlaagte River are identified as being the most important areas for reptiles at the site due to the increased habitat diversity and refuge options that this area provides. However, a West-Coast endemic, Gronovi's Dwarf Burrowing Skink Scelotes gronovii (NT) is confirmed present at the site and represents the most significant reptile observation from the site. This species occurs from Doringbaai in the north to Robben Island in the south, and inland to Graafwater. The current development is located at the northern distribution limit of this species which does not appear to occur north of the Olifants River. The loss of less than 100ha of habitat at the site, not all of which is currently intact, would not be likely to significantly impact the local or regional population of this species. The majority of the site is classified as an Ecological
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Support Area, apart from the dunes in the east and Sandlaagte River which are CBA 1. The development would not impact the CBAs as the footprint is restricted to the transformed areas and ESA. While the ESA would experience some habitat loss, this would not be likely to impact the overall supporting function of the ESA and lead to cascading impacts on adjacent CBAs. As such, the impact of the development on the ecological functioning of the area is likely to be relatively low and no significant disruptions in ecological processes are likely to occur.
The impacts associated with the development of the Juno WEF are likely to be of moderate to low significance after mitigation and there are no fatal flaws or high post-mitigation impacts associated with the development. As such there are no terrestrial ecological reasons for the development not to proceed to the EIA phase.
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9 AVIFAUNA ASSESSMENT
9.1 Methodology Approach This Scoping study included the following steps: A review of available published and unpublished literature on bird interactions with wind energy facilities (WEF) that summarise the issues and potential impacts involved, and the current level of knowledge. Data sources were examined including bird atlas records on the avifauna of the area and previous studies of bird interactions with wind energy facilities and electrical infrastructure associated with them; An annotated list of the avifauna likely to occur within the impact zone of the proposed WEF to be compiled using a combination of the existing distributional data from published atlases and our previous experience of the avifauna of the area; A short-list of priority bird species (defined in terms of conservation status and collision-prone vulnerability) which may be impacted by the proposed WEF was highlighted. These species were considered as adequate surrogates for the local avifauna generally, and mitigation of impacts on these species was considered likely to cover less sensitive bird species that may also be affected; Three site visits were undertaken to the larger site from September 2017 to March 2018 to determine which species actually occur in the wind farm and in which habitats. The precise turbine placements were not available at the time of the field trip, so we undertook general walking, driving and Vantage Point surveys to cover the entire area; A summary of more likely and significant impacts of the WEF on the local avifauna will be drawn up.
Data sources used The following data sources and reports were used in the compilation of this report: Information on the biology (Hockey et al. 2005), distribution (Harrison et al. 1997) and conservation status (Taylor et al. 2015) of southern African birds was consulted. Recent data from around the wind farm area were extracted from the Southern African Bird Atlas Projects (SABAP), which were obtained from the Animal Demography Unit website http://sabap2.adu.org.za/index.php for the relevant quarter- degree square (SABAP 1) and the “pentads” of 5’ x 5’ from (SABAP 2: 3140_1810, 3140_1815, 3145_1815, 3145_1810). One pentad covers approximately 7-km x 8-km. From these pentad records (n = 87 cards, accessed April 2018) we compiled a list of the avifauna likely to occur within an area of about 224 km2 around the proposed wind farm. We combined these data, with our own visit to the area from September 2017 to March 2018 and previous experience/knowledge of the local avifauna, undertaken on trips made through this area over the last ten years; Conservation status and endemicity of all species considered likely to occur in the area was determined from the national Red-list for birds (Taylor et al. 2015), and the comprehensive summary of southern African bird life-histories (Hockey et al. 2005); The important bird areas (IBA) assessment for South Africa (Barnes 1998, Marnewick et al. 2015) were also consulted to determine if any areas had been so designated; The avian-wind Sensitivity Map of the Birds and Renewable Energy Specialist Group (BARESG) of South Africa http://www.birdlife.org.za/conservation/birds-and-wind-energy/windmap/325-windmap was used to characterise the general area around Strandfontein for national avian sensitivity. This gives an overall sensitivity ranking for birds within each pentad based on numbers of Red Data birds, roosts, nesting areas, wetland bird accumulations and other significant avian hot-spots in South Africa; The list of the top 100 collision-prone species as designated by Birdlife South Africa was used to rank those species recorded on site into those most sensitive to fatality (priority species) due to turbines and power lines; Relevant EIA reports and reviews of the potential impacts on birds at other WEFs in South Africa were also assessed for birds both regionally (Simmons and Martins 2015) and nationally (Ralston-Paton et al. 2017).
9.2 Baseline Environment
9.2.1 Bird microhabitats Bird habitat in the region consists of fairly uniform vegetation type of coastal shrubs and succulent plants. The vegetation includes flowering shrubs and endemic plants such as Lampranthus and Tylocodon species. There are a few alien trees on site (e.g. Eucalyptus) and several farm reservoirs, wind mills and natural pans that were dry and unvegetated in the summer trip. Few grasses are found, making the lark species diversity rather slim. No Eskom transmission lines or pylons are found within the extended site,
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reducing the likelihood of larger raptors using the pylons as nesting sites. The tallest man-made structure on site is the 80m wind-mast.
The most recent data available from the SABAP2 bird atlas of the Avian Demography Unit was downloaded from http://sabap2.adu.org.za/map_interactive.php. This bird species list is based on 87 full protocol cards submitted from 2008 to 2018. Since this is inclusive of records from the visits, it represents a comprehensive list on-site record. This not only allows a “reporting rate” to be generated (a guide to how likely each species is to occur in the area) but it allows one to determine the likelihood of occurrence of sensitive species such as the red-listed bustards and birds of prey.
9.2.2 Bird sensitivity in the area The Juno wind farm lies in an area of medium-high avian sensitivity according to Birdlife South Africa’s avian sensitivity map. This indicates that priority species are likely to occur there, and mitigations will probably be necessary. The proposed farm lies just outside the Olifants River Estuary Important Bird Area (IBA: Marnewick et al. 2015). This area holds numerous wading birds, as well as breeding Black Harriers (RE Simmons unpubl data) and wetland species including flamingos and pelicans. It is unlikely that all of these species will fly inland over the proposed farm, but this must be determined during the 12-months of pre-construction monitoring.
Of note for this preliminary assessment is that no detailed Bird Sensitivity Modelling has been undertaken. This is due to the 12-months pre-construction monitoring having not been completed at Scoping phase, and because of the nomadic movements of red data birds that respond to rainfall. Given the very dry spell over the last rain season we may underestimate the numbers of such species and thus a full 12 months monitoring is required. The final season of bird monitoring will be conducted during the EIA phase and a detailed Bird Sensitivity Map will be produced within the EIA Report.
9.2.3 Priority species in the study area According to SABAP2 records and incorporating the on-site records, species richness around the study area is 131 species. This represents about 14% of all species recorded in Southern Africa. Among these were 16 highly collision-prone (within the top 100 most collision-prone species in southern Africa). Six of these species are threatened red-listed species in South Africa (Taylor et al. 2015). These species are, in order of susceptibility to collision: Verreaux’s Eagle, Martial Eagle, Black Harrier, Ludwig’s Bustard, White Pelican, Secretary bird (Table 9.1).
Table 9.1: All (16) collision-prone species in the top 100 of Birdlife South Africa’s listing including the red data birds (in bold) recorded in bird atlas data (2008-2018) in the proposed Juno WEF.
Susceptibility to: Reporting Collision Common name Scientific name Red-list status Rate* Disturbance Rank**
Verreaux’s Eagle Aquila verreauxii Vulnerable 2.3% 2 Moderate Polemaetus 2/15 = Martial Eagle Endangered 5 High bellicosus 13%a Black Harrier Circus maurus Endangered 9.2% 6 High Pelecanus White Pelican Vulnerable 9.2% 8 Moderate onocrotalus Ludwig’s Bustard Neotis ludwigii Endangered 6.9% 10 Moderate Saggitarius Secretary bird Vulnerable 6.9% 12 Moderate serpentarius African Fish Eagle Haliaetus vocifer Not threatened 1.2% 27 moderate Southern Black Afrotis afra Not threatened 29.9% 35 Low Korhaan Jackal Buzzard Buteo rufofuscus Not threatened 16.1% 42 Low Peregrine Falcon Falco peregrinus Not threatened 2.3% 45 moderate
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Susceptibility to: Reporting Collision Common name Scientific name Red-list status Rate* Disturbance Rank**
Booted Eagle Aquila pennatus Not threatened 5.8% 55 Low Lesser Kestrel Falco naumanni Not threatened 4.6% 62 low Pale Chanting Melierax canorus Not threatened 44.8% 73 Low Goshawk Black-shouldered Kite Elanus caerulescens Not threatened 17.2% 96 Low Greater Kestrel Falco rupicoloides Not threatened 11.5% 97 low Spotted Eagle Owl Bubo africanus Not threatened 1.2% 100 low * a measure of the frequency of occurrence (No. of times recorded/total number of atlas cards). ** Ranking on Birdlife South Africa’s listing of the top 100 collision-prone species (Ralston-Paton et al. 2017). a In three site visits (5 d each) this species was seen twice in 15 days field work = 13% reporting rate.
The listing above shows that 16 species of priority birds are potentially likely in the wind farm. Of these, the 6 red data species are of most concern and the 12-months monitoring programme highlights these species. The Reporting Rate, a measure of the likelihood of occurrence, indicates that Martial Eagles, Black Harriers and pelicans are the most likely red-data species to occur on site (Table 9.1). They occur at low frequencies, typically below 10%. Among the other priority species, the Pale Chanting Goshawk and the Southern Black Korhaan are the most likely to occur on site. The bustards are of concern given their highly nomadic nature in relation to rainfall (Shaw 2013), despite atlas data suggesting a low frequency of occurrence. Eagles are prone to collision due to their heavy wing-loading or skull morphology (bustards and cranes). Of these, six species are Red-listed including the bustards (1 species), raptors (4 species) and wetland species (1 species). These species will require special mitigation if they occur with high frequency over the proposed wind farm site. There are 8 other raptor species that are not red-listed (Table 9.1) including falcons (3 species), eagles (2 species), buzzards (1 species), kites (1 species), and chanting goshawk (1 species) that are collision-prone. These species must be given special attention, particularly along the existing and proposed power lines.
9.3 Assumptions and Limitations Inaccuracies in the sources of information may bias the study. The SABAP1 data for this area is now 20- years old (Harrison et al. 1997), and this area is relatively remote and seldom visited. However, a healthy set of 87 atlas cards exists for the four pentads around the Juno WEF and these data form the basis for this study. Some of the data comprise this SABAP data set from the site visits since October 2016 (Simmons and Martins 2016) allowing us an insight into the birds there. No surveys, however detailed, can give a full picture of all species passing through an arid region, and such lists are statistically likely to miss the rarest species.
9.4 Preliminary Assessments • A suite of 13 raptors, one species of bustard, one korhaan and one wetland species were identified as potentially at risk given their presence in the area and their vulnerability to collision; • The probability that they will be affected by the proposed wind energy facility is insufficiently known at present – it is dependent upon their use of the area and the numbers present; • Preliminary assessment from three site visits to the full area recorded only 5 collision-prone species on or near the site: red data Ludwig’s Bustards (in large numbers), and Martial Eagle, as well as Southern Black Korhaan, resident Jackal Buzzards and Booted Eagles (Simmons and Martins 2016). This frequency of birds is not unexpected given the generally poor rainfall. Other collision-prone species are expected with once the 12-months of pre-construction work is undertaken; • A preliminary list of possible mitigations at the start of this project would include: (i) turbines should avoid hill tops and ridges (because raptors use updrafts there), or (ii) above the rocky outcrops in the southern sections of the farm (where eagles hunt their prey), or (iii) near the pans in the northern sections where wetland species and bustards may occur when flooded.
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9.4.1 Construction Phase Impacts Impact Phase: Construction Phase Impact description: Disturbance through construction of a building works depot, turbines themselves, roads, and associated human activity, noise of construction. Birds are easily disturbed by human presence, vehicle traffic and the effect of noise. Some studies suggest that construction-disturbance of birds is greater than operational disturbance (Pearce-Higgins et al. 2009). This is particularly so with breeding birds who require safe areas and no disturbance before they invest in the subsequent generation. Larger species tend to be more sensitive to human presence than smaller species with smaller territories. Disturbance therefore is likely to influence all of the collision-prone species listed in Table 9.1. Several red data birds occur that are ground nesting species. The bustards and the Black Harrier both fall into this category and human presence is especially likely to negatively affect these species. Tree-nesting species (e.g. Jackal Buzzards) are less prone to disturbance during construction. With no mitigation birds moving into the site after rains to breed are likely to move away with excessive disturbance such as noise, human presence or high-volume vehicle traffic. Extent Duration Intensity Status Significance Probability Confidence Without M M M Negative H M M Mitigation With M L M Negative M M-L M Mitigation Can the impact be reversed? Yes. Construction sites can avoid the high-risk areas and the breeding periods which are generally August – December. Breeding birds are likely to return once construction is complete. Will impact cause irreplaceable No, the disturbance is likely to last for the duration of the construction loss or resources? and some birds will return to the area to breed. Bustards for example are known to breed within wind farm sites in the E Cape. Black Harriers are also known to breed within wind farm sites Can impact be avoided, Impacts can be minimized and largely avoided if areas where sensitive managed or mitigated? collision-prone species occur are themselves buffered. New roads will need to avoid such areas, and construction work should be minimized at times when red data species are breeding or congregating (bustards form leks shortly after arriving with the rains). Nest cannot be moved so it’s important to identify all areas where the red data species congregate or breed, and avoid them. Mitigation measures: Excessive noise (after hours, near known sensitive sites) should be avoided; Sensitive areas identified in the full EIA phase should be buffered (recommended buffer is 500 m); Bustard lekking areas should be buffered by 500 m for all roads and turbine positions; Pans are often congregation areas for wetland species or terrestrial birds that come to drink. We recommend no construction around these pans and suggest a buffer. Impact to be addressed/ Yes. This is essential in identifying sensitive areas. This can only be further investigated and finalised when all data are in (all records for all months) because of the assessed in Impact Assessment sensitivity of gathering data in the rainy season. Phase?
9.4.2 Operational Phase Impacts Impact Phase: Operational Phase Impact description: Displacement of priority species One main impact of wind farms is the long-term displacement of species that naturally occurred. Birds move away either because the turbines and presence of vehicles disturbs them, or kills their mates, or makes their breeding success lower and they move to more successful breeding sites. This reduces the overall breeding density of species such as harriers (Wilson et al. 2017) and other smaller species move away (Pearce-Higgins et al. 2012). Extent Duration Intensity Status Significance Probability Confidence
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Without L M L Negative M M M Mitigation With L M L Negative M M M Mitigation Can the impact be reversed? Yes, with careful planning displacement can be avoided by allowing corridors between turbines, and avoiding disturbing or killing priority species (pairs that are unsuccessful are more likely to move away). Will impact cause irreplaceable Probably, yes. Global research tends to show that birds do slowly move loss or resources? away from wind farms and the areas is lost to certain species (Pearce- Higgins et al. 2009, Wilson et al. 2017) Can impact be avoided, Displacement can be avoided by allowing corridors between turbines. managed or mitigated? But few mitigations seem tried and tested. In some cases, it is however, better to have birds displaced because it may reduce the chance of those species being killed by the wind farm. Mitigation measures: Providing corridors between turbine strings to allow flyways for birds to traverse the wind farm. Impact to be addressed/ Yes, Displacement can be assessed by recording the presence of birds further investigated and on the wind farm and a control site. In the operational phase the assessed in Impact Assessment density of birds on the wind farm and the control site can then be Phase? compared – with and without turbines. This allows a direct test of the idea of which species are displaced.
Impact Phase: Operational Phase Impact description: Direct impact and death of priority species The third main impact of wind farms is the direct impact of birds being killed. Birds move away either because the turbines and presence of vehicles disturbs them, or kills their mates, or makes their breeding success lower and they move to more successful breeding sites. This reduces the overall breeding density of species such as harriers (Wilson et al. 2017) and other smaller species move away (Pearce-Higgins et al. 2012). Extent Duration Intensity Status Significance Probability Confidence Without L M M Negative H H M Mitigation With L M M Negative M M M Mitigation Can the impact be reversed? Yes, with careful planning displacement can be avoided by allowing corridors between turbines. Will impact cause irreplaceable Probably, yes. Global research tends to show that birds do slowly move loss or resources? away from wind farms and the areas is lost to certain species (Pearce- Higgins et al. 2009, Wilson et al. 2017) Can impact be avoided, Mortality can be avoided by three main methods: (i) placing turbines managed or mitigated? outside areas identified as high risk during the pre-construction phase. This is the single most important mitigation measure. (ii) in high- volume areas, shutting down problem turbines at particular times or season, (iii) for turbines found to kill mor4e than 1 red data priority species per year, painting a single blade of each turbine black, to enhance visibility. This was successfully undertaken by Stoke et al. (2017) to reduce eagle mortality in Norway (above). Mitigation measures: Providing corridors between turbine strings to allow flyways for birds to traverse the wind farm. Impact to be addressed/ Yes, Mortality can be directly gauged with weekly carcass searches further investigated and within 80 m radius of each turbine over a minimum of 12 months but assessed in Impact Assessment preferably longer. This allows the identification of those species most at Phase? risk to be recorded and problem turbines to be identified and mitigation to be enacted at them.
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9.4.3 Cumulative Phase Impacts Impact Phase: Cumulative Phase Impact description: Displacement and direct mortality of priority species Displacement and direct mortality reduces the overall breeding density of species such as harriers (Wilson et al. 2017) while other smaller species move away (Pearce-Higgins et al. 2012). Most birds killed in South Africa are raptors (36%) and 5.5% of all species are red-listed (Ralston-Paton et al. 2017). From calculations above, the estimated number of red data birds killed by all wind farms, solar farms and power lines within 35 km of Juno is estimated at 51. Extent Duration Intensity Status Significance Probability Confidence Without H M M Negative H H M Mitigation With M M M Negative M M M Mitigation Can the impact be reversed? Yes with careful planning and mitigation, displacement and direct mortality can be avoided at all wind and solar farms in the area. Will impact cause irreplaceable Probably, yes. Global research tends to show that birds do slowly move loss or resources? away from wind farms and the areas is lost to certain species (Pearce- Higgins et al. 2009, Wilson et al. 2017). An estimated 50 threatened birds may die at the combined number of wind or solar farms and associated power lines. Can impact be avoided, Yes they can, but all wind farms need to actively enact mitigations and managed or mitigated? the recommended mitigations need to be enforced by the DEA or an independent body like Birdlife South Africa. Operational wind farms that are killing birds need in depth studies and carcass searchers to determine what is being killed and where. Once problem turbines are identified mitigations (black-blade and shut-down on demand) can be tested at these turbines. Mitigation measures: Providing corridors between turbine strings to allow flyways for birds to traverse the wind farm; If birds continue to be displaced or killed then areas outside the wind farms involved can be managed to attract the birds away, and the habitat on the farms can be manipulated to reduce its attractiveness, especially to raptors and bustards. Impact to be addressed/ Yes, Displacement can be assessed by recording the presence of birds further investigated and on the wind farms and their control sites. In the operational phase the assessed in Impact Assessment density of birds on the wind farms and control sites can then be Phase? compared – with and without turbines. This allows a direct test of the idea of which species are displaced. Each operational wind farm should be surveyed for a minimum of 24 months to determine if they are killing excessive numbers of red data birds. Black-blade mitigation, as the most cost-effective and tested method, should be implemented at those farms exceeding a threshold of threatened species being killed.
9.5 Summary / Conclusion This Scoping report has identified the following species that require further assessment of the local population: 16 highly collision-prone species including six red data species (Ludwig’s Bustard, White Pelican, Black Harrier, Verreaux’s Eagle, Martial Eagle and Secretarybird) that will occur or pass through the site. Other species that feature prominently in fatality records from South African wind farms (e.g. Jackal Buzzards) are also likely to be impacted and all may require mitigation depending on their frequency of occurrence and spatial use of the proposed site. Pans in the north-east of the site will also require close study as they are likely to attract wetland species at times of flooding and should be avoided for development. Issues related to the collision and electrocution of birds should be investigated in more detail during the full EIA phase. In particular, the significance of bird collisions with the turbines will be assessed to determine whether the risk warrants mitigation such as no-go areas for turbine placement. This will be
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assessed mainly in terms of (i) the actual abundance of priority bird species in the area, and (ii) the distribution of relevant microhabitats and food resources. Further monitoring will give better data on the use of different areas of the wind farm by these and other birds.
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10 BAT ASSESSMENT
10.1 Methodology A desktop study was conducted to compile the most recent and accurate information available, in order to provide a better evaluation of all conditions present within the study area. Data sources were consulted in order to assess the species likelihood to occur within the proposed Juno WEF area. Furthermore, the following steps were taken: Based on a desktop review and considering all literature references available, a list of all bat species with potential to occur within or in close proximity to the site was compiled. Literature references and local farmers were consulted concerning any available information regarding presence of known roosts in the vicinities of the proposed site. Literature review was conducted as well as regarding wind developments in South Africa or similar environments. All listed species were assessed at a national level in terms of endemism, population trend, habitat preferences and conservation status. All listed species were classified in terms of probability of occurrence within the site, considering several criteria evaluated in conjunction with one another, such as historical confirmation of species in the area, presence of known roosts and presence of suitable habitats, etc. The vulnerability of these species to potential impacts caused by wind energy developments (in terms of potential collision risks with wind turbines) was evaluated according to the most recent version of the South African Good Practice Guidelines for Surveying Bats in Wind Farm Developments – 4th Edition (Sowler & Stoffberg, 2016). A short list of sensitive species was identified to which the assessment and monitoring programme should pay special attention to. Sensitive species were identified by means of a specific structured decision process based each species’ conservation status, vulnerability to collision and ecological characteristics such as migratory behaviour. A desktop study, based on all the available information such as topographical maps of South Africa, Google™ Earth imagery, and Geographical Information System software was conducted for a preliminary evaluation of the area. A reconnaissance field visit was conducted in February 2016 to achieve an initial understanding of its characteristics. It is important to characterise the study area in terms of the vegetation and habitat present on site. The method used for vegetation classification is that developed by Mucina & Rutherford (2006). At a micro level, more important than the biomes, is the presence of specific structures which shaped the local occurrence and bat distribution within the site. Bat abundance and movement are related to vegetation features such as tree-lined avenues, hedges and other relevant features which could potentially be used as roosts (open water bodies, cliff faces, buildings with accessible roofs or attics etc.). It is therefore essential to characterise the study area in these terms. Google™ Earth imagery and most importantly, field work, was used to identify the available micro-habitats on site.
The reconnaissance visit conducted between 16th and 19th August 2016 formed part of the bat pre- construction monitoring programme, implemented at the proposed Juno WEF. Therefore, all the methodologies conducted for this scoping assessment were in compliance with the most recent version of the South African Good Practice Guidelines for Surveying Bats in Wind Farm Developments – 4th Edition (refer to Sowler & Stoffberg, 2016 for more details). The following methodologies were implemented: Active acoustic monitoring to characterise the bat community occurring within the area of the Wind Energy Facility. These surveys consisted of vehicle based transects that covered the main existent bat relevant biotopes. Passive monitoring to determine preliminary patterns of bat activity in the study area. Information collected through this methodology will inform the final environmental impact assessment. Roost search and inspection to determine the usage of the area by bat species within and in close proximity to the Wind Energy Facility. Potential roosts were first identified during desktop analysis in Google earth and inspected during fieldwork. The evidence of bats’ presence was recorded (such as guano accumulation, bat corpses or insect remains). Special features observations to register the main features potentially relevant for bats located in the vicinity of the sites (e.g. water bodies, tree stands and tree-lined avenues and vegetated hedges, etc.). All of the aforementioned methodologies were implemented within the wind energy facility and its immediate surroundings. The methodologies implemented in this first reconnaissance visit were intended to provide a preliminary indication of the bat community present in the area, utilisation of the proposed area by bats and the importance of the various habitats for the bat community.
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10.2 Baseline Environment
10.2.1 Bat micro-habitats Topography at the proposed area is characterised by flat plains with occasional gentle undulations and without any remarkable features which might condition bat distribution. The Leipoldtville Sand Fynbos vegetation is found in coastal plains, slightly rolling in places, covered with an upper open stratum of emergent shrubs in clumps, and the Namaqualand Strandveld vegetation is dominated by a plethora of erect and creeping succulent shrubs as well as non-succulent shrubs. Several bat species are however highly associated with the type of habitat characteristics of arid and semi-arid habitats such as the Egyptian slit-faced bat (Nycteris thebaica), the Lesueur’s wing gland bat (Cistugo lesueuri), the Cape horseshoe bat (Rhinolophus capensis), or the Egyptian free-tailed bat (Tadarida aegyptiaca). Apart from the bat species that are naturally associated with this biome, other species, which have a more widespread distribution may also occur, such as the Cape serotine (Neoromicia capensis). Potential bat micro habitats identified at the site, as identified during the field visits and desktop analysis of the area are described below.
Water features and riverine vegetation The study area has few water features. Regardless, the water that is present on site comes forth as man- made reservoirs (Photograph 10.1). The presence of bats are not only restricted to water availability but also to insect abundance due to the associated vegetation present. These water features are important for bat species, especially if surrounded with well-developed vegetation. Some bat species which may occur at the site are specifically associated with these features, such as the Lesser woolly bat, the Dusky pipistrelle and the Lesueur's wing-gland bat. From these species only the Lesueur's wing-gland bat has the potential (moderate) to occur at the proposed Juno WEF.
Photograph 10.1: Reservoir found in the Juno WEF proposed farm portions
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Natural vegetation The natural vegetation within the proposed development is composed by one main vegetation structure: extended lower plains with medium to small dimensions’ shrubs and some trees (Photograph 10.2). Bat species associated to the grassland biome, such as the Natal long-fingered bat, the Lesueur's wing-gland bat and Egyptian slit-faced bat are most likely to be associated to these areas. Photograph 10.2: Examples of areas of natural vegetation within the proposed area for Juno WEF
Buildings Despite being mostly composed by areas of natural vegetation; man-made infrastructures are present. A few buildings were observed, most of them being farming sheds, and one that is currently occupied by farm labourers (see Photograph 10.3). This location as well as other with similar characteristics may be important for several bat species which use them for roosting, such as the Egyptian slit-faced bat, the Cape serotine, the Geoffroy's horseshoe bat and the Egyptian free-tailed bat.
Photograph 10.3: Man-made infrastructures with suitable characteristics for roosting of bat species
Trees Another micro-habitat present, within and in the area immediately adjacent to the proposed site, which is important for a number of bat species, are stands of trees. In the study area, such trees are scattered
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through the shrubland (Photograph 10.4). These locations may have two different utilisations by the different bat species potentially present in the area: they may be used as roosts by tree-dwelling species such as the Egyptian silt-faced bat, the Cape serotine or the the Egyptian free-tailed bat. On the other hand, trees may also be used as feeding roosts during the night by other bat species, such as the Geoffroy’s horseshoe bat, which then roost during the day at separate locations (usually caves or mines).
Photograph 10.4: Scattered trees present in focus area
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10.2.2 Bat Community It was possible to determine that at least 19 bat species have the potential to occur within or in the immediate vicinity of the site (Error! Reference source not ound.10.1). Foraging Foraging Collision South habits habits risk Probability Scientific Common Africa Habitat
Family Roosts (Sowler & of name name Red preferences Flight Flight type Stoffberg occurrence List Height 2014)
IUCN Caves, culverts and Nycteris Egyptian silt- Savannah and NYCTERIDAE LC LC trunks of large Clutter forager LH Low Moderate thebaica faced bat Karoo biomes trees. Miniopterus Natal long- Savannas and Clutter-edge Medium - MINIOPTERIDAE LC NT Caves MH, HH High fraterculus fingered bat grasslands forager High Broken terrain in Lesueur's high altitude Clutter-edge Cistugo lesueuri wing-gland LC NT Rock crevices montage MH Low Low forager bat grassland, near water Arid and semi- Angolan wing- arid, riverine Clutter-edge Cistugo seabrai LC VU Buildings MH Low Low gland bat vegetation of dry forager river beds Eptesicus Long-tailed Caves and rock Woodland and Clutter-edge LC LC MH, HH Medium Moderate hottentotus serotine crevices rocky regions forager Namibian Arid desert, VESPERTILIONIDAE Laephotis Narrow crevices in Clutter-edge long-eared LC NE fynbos, riparian MH Low Low namibensis rock forager bat vegetation Clutter-edge Clutter-edge Caves. Absent from Temminck's forager (only forager (only Medium - Myotis tricolor LC NT flat and featureless MH. HH Low myotis capture aerial capture aerial High terrain prey) prey) Low-lying savannas, well- Clutter-edge Nycticeinops Schlieffen's Rock crevices and wooded places, forager LC LC - Medium Low schlieffeni twilight bat houses riparian (captures vegetation, aerial prey) drainage lines
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Clutter edge Hypsugo Anchieta's Riparian LC NT - and clutter - Low Low anchietae pipistrelle vegetation forager Semi-arid areas to Under the bark of Neoromicia montage Clutter-edge Medium - Cape serotine LC LC trees, foliage and MH High capensis grassland, forests forager High buildings and savannah Well-wooded Neoromicia Foliage and Clutter-edge Medium - Banana bat LC LC habitats, riparian MH Low nana buildings forager High forest Woodland Neoromicia Clutter-edge Medium - Zulu serotine LC LC - savanna, riparian MH Low zuluensis forager High vegetation Fynbos and Rhinolophus Cape LC NT Caves and mines succulent Karoo Clutter forager LH Low Moderate capensis horseshoe bat biomes Savannah, RHINOLOPHIDAE Rhinolophus Geoffroy's LC NT Caves and mines woodland and Clutter forager LH Low Moderate clivosus horseshoe bat riparian forest. Rhinolophus Darling's Savanna and LC NT Caves and mines Clutter forager LH Low Low darlingi horseshoe bat woodland Narrow cracks, Rocky habitats in Sauromys Robert's flat- Open-air LC LC under slabs of woodland, fynbos HH High Low petrophilus headed bat forager exfoliating rock or arid scrub Caves, rock MOLOSSIDAE crevices, under Semi-arid scrubs, Tadarida Egyptian free- exfoliating rocks, savannah, Open-air LC LC HH High High aegyptiaca tailed bat hollow trees, behind grassland and forager the bark of dead agricultural land trees and buildings Taphozous Mauritian Rock faces, tree Savannah Open-air EMBALLONURIDAE LC LC HH High Low mauritianus tomb bat trunks, walls woodland. forager Rousettus Egyptian Medium - PTEROPODIDAE LC LC Caves Forest Clutter forager MH, HH Low aegyptiacus rousette High Table 10.1: List of species with possible occurrence at the Juno WEF study area. IUCN (2014) and South Africa Red List (Friedmann & Daly 2004): NT – Near Threatened; LC – Least Concerned; NE – Not Evaluated; Flight height: LH – Low Height (generally below 2 meters); MH – Medium Height (generally between 2 and 10 meters); HH – High Height (generally above 10 meters).
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10.2.3 Sensitivity mapping for Juno WEF It is important to conserve the trees and roosts in the south and southwest border of the Juno WEF, and also the few water bodies / reservoirs that exist in the proposed area.
Large Scale Sensitivity Migratory bats in South Africa include the Egyptian silt-faced bat Nycteris thebaica, Natal long-fingered bat Miniopterus natalensis, Temminck's myotis Myotis tricolor, Bushveld horseshoe bat Rhinolophus simulator, African straw-coloured fruit bat Eidolon helvum and Egyptian rousette Rousettus aegyptiacus (Monadjem et al. 2010). Placement of wind energy facilities in close proximity to roosts of migratory species is likely to lead to seasonal high fatality events. Therefore, considering that these species undertake migrations that can go from 100km to several thousand km, a compromise buffer of 50km was considered around known roosts with migratory species.
Small Scale Sensitivity According to the desktop analysis and data collected in the field, the general area of the site is being used by sensitive species, with high risk of collision with wind turbines (e.g. Long-tailed house bat and the Egyptian free-tailed bat), though with generally low activity levels. Roost presence and specific important feeding grounds were difficult to identify. However, there are 4 known potential roosts located in the WEF site and in the proximities. Therefore, until more information has been collected regarding bat activity in the general area of the proposed Juno WEF farm portions, it is classified as having a low sensitivity. Considering the Best practice recommendations the sensitivity areas were delineated according to the buffer areas indicated in the “Bat Sensitivity Buffer Zone Recommendations” of the South African Bat Assessment Advisory Panel (SABAAP) (SABAAP 2013) and the fourth edition of the South African Good Practice Guidelines for Surveying Bats at Wind Energy Facility Developments - Pre-construction.
Figure 10.1 presents additional features of interest which should be avoided from wind turbine placement, such as: Water features / Reservoirs: As aforementioned a 200m buffer should be applied around water features with suitable characteristic for bat communities, e.g. the ability to hold water throughout the year, and the presence of well-developed vegetation in the margins. In this case, the only features with interest are three reservoirs that exist in the development area. Tree lines: The same buffer area (200m) should be considered as a no-go area around tree lines, due to the importance of this feature as a commuting area for bats (Rodrigues et al. 2008). Buildings: Bats use buildings and similar infrastructure to roost. This behaviour increases the risk of negative impacts on the local populations, whether by collision with wind turbines or by displacement from roosting locations. Therefore, after the confirmation of utilisation of the structures present within the proposed area, a 500m buffer is recommended.
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Figure 10.1 Preliminary sensitivity mapping of the high sensitivity areas for bats at the proposed Juno WEF (background image: Virtual Earth Satellite Imagery)
10.3 Assumptions and Limitations The bat assessment of the study area will be dependent on the accuracy of both primary (data collection) and secondary data sources. Any inaccuracies or lack of information in the bibliographic sources consulted could limit this study. In particular, 5 years have passed since the leading literature that is available for bat distribution in South Africa has been updated (Monadjem et al. 2010).
10.4 Preliminary Assessments
10.4.1 Construction Phase Impacts Impact Phase: Construction Phase Impact description: Destruction of natural vegetated areas Destruction of natural vegetated areas due to platforms construction, workstation and substation construction, internal access roads construction, and turbines, underground cabling and overhead power lines installation. Extent Duration Intensity Status Significance Probability Confidence Without L H M Negative M M M Mitigation With L H L Negative M M M Mitigation Can the impact be reversed? Yes, The impact can be reversed naturally or through a habitat recovery program. Will impact cause irreplaceable Yes, as naturally vegetated areas would be permanently replaced by loss or resources? new infrastructures. Can impact be avoided, Yes, as long as all pre-defined naturally vegetated areas are avoided managed or mitigated? when construction takes place. Mitigation measures: Avoidance of infrastructure siting (wind turbines, roads, powerlines, sub-station infrastructures or other associated buildings) in no-go areas and wind turbines in areas of higher bat sensitivity; Activities of clearance and removal of vegetation should be keep to minimum extent possible; Beneficiation of existing accesses should be conducted strictly to the extent necessary; The area of intervention should be identified and delimitated prior to the beginning of the work; Movement of machinery, vehicles and persons should be restricted to the existing roads and avoid the existing natural areas.
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Impact to be addressed/ Yes. further investigated and assessed in Impact Assessment Phase?
10.4.2 Operational Phase Impacts Impact Phase: Operational Phase Impact description: Fatality of individuals Fatality of individuals due to collision with turbine blades or barotrauma caused by turbines operation. Extent Duration Intensity Status Significance Probability Confidence Without L M M Negative M H M Mitigation With L M L Negative M M M Mitigation Can the impact be reversed? No, as any fatalities would be considered as a loss to the community. Will impact cause irreplaceable Yes, as it could potentially cause local extinctions, if not appropriately loss or resources? managed. Can impact be avoided, Yes, The impact can be avoided to the maximum extent possible with managed or mitigated? the correct avoidance & mitigation measures, as listed below. Mitigation measures: Avoidance of turbines installation in highly sensitive areas for bats; A monitoring plan is recommended during operation phase and, if high levels of mortality are observed during operational phase, management actions should be put into action to mitigate fatality; It is recommended that no tall vegetation should be allowed within the 200m buffer around the wind turbines to reduce the suitability of the areas for bat foragers; A bat monitoring program should be implemented in order to determine the actual impacts of the wind energy facility on the bat community, as well as the implementation of mitigation measures, such as the utilization of red lights in the turbines, instead of white, in order to minimise insect attraction and bat foraging behaviours near the turbines. Impact to be addressed/ Yes. further investigated and assessed in Impact Assessment Phase?
Impact Phase: Operational Phase Impact description: Disturbance of bat community Disturbance of bat community due to the increase of people and vehicles in the area, and destruction of roost locations. Extent Duration Intensity Status Significance Probability Confidence Without L M M Negative M M M Mitigation With L M L Negative M M M Mitigation Can the impact be reversed? Yes, Either through temporary or permanent displacement of individuals. Will impact cause irreplaceable No, As long as high-sensitivity areas are avoided, the impact is unlikely loss or resources? to cause much disturbance to any roosting sites and is unlikely to affect the behavior of the community. Can impact be avoided, Yes, The impact can be avoided and mitigated as long as the managed or mitigated? avoidance/mitigation measures (as listed below) are adhered to. Mitigation measures:
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Avoid the presence of people and vehicles in the high sensitivity areas as possible; Maintenance operations, during the operation phase, should avoid the periods most sensible for bats; Lower the levels of noise whenever possible around high sensitivity areas for bats. Impact to be addressed/ Yes. further investigated and assessed in Impact Assessment Phase?
10.4.3 Decommissioning Phase Impacts Impact Phase: Decommissioning Phase Impact description: Disturbance of bat community Disturbance of bat community due to the increase of people and vehicles in the area, and destruction of roost locations. Extent Duration Intensity Status Significance Probability Confidence Without L L M Negative M M M Mitigation With L L L Negative L L M Mitigation Can the impact be reversed? Yes, Either through temporary or permanent displacement of individuals. Will impact cause irreplaceable No, The impact will only be temporary and should not have a loss or resources? significant effect on the population. Can impact be avoided, Yes, As long as the appropriate management/mitigation measures are managed or mitigated? followed (as listed below). Mitigation measures: Avoid the presence of people and vehicles in the high sensitivity areas as possible; Whenever possible schedule activities in order not to cause disturbance during bat breeding season; Lower the levels of noise whenever possible around high sensitivity areas for bats; Avoid dismantling works during the night and avoid the destruction or disturbance of identified roosting sites. Impact to be addressed/ Yes. further investigated and assessed in Impact Assessment Phase?
10.4.4 Cumulative Phase Impacts Impact Phase: Cumulative Phase Impact description: Accumulate of disturbance of bat community Disturbance of bat community due to the increase of people and vehicles in the area, and destruction of roost locations in the region. Extent Duration Intensity Status Significance Probability Confidence Without M M M Negative M M M Mitigation With M M L Negative M M M Mitigation Can the impact be reversed? Yes, Either through temporary or permanent displacement of individuals. Will impact cause irreplaceable No, As long as high-sensitivity areas are avoided, the impact loss or resources? (cumulative) is unlikely to cause much change or disturbance to any roosting sites and is unlikely to affect the behavior of the bat community.
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Can impact be avoided, Yes, The impact can be avoided and mitigated as long as the managed or mitigated? avoidance/mitigation measures (as listed below) are adhered to. Mitigation measures: Avoid the presence of people and vehicles in the high sensitivity areas as possible; Maintenance operations, during the operation phase, should avoid the periods most sensible for bats; Lower the levels of noise whenever possible around high sensitivity areas for bats; A bat monitoring program should be implemented in order to determine the actual impacts of the wind energy facility on the bat community and evaluate if the presence of other projects causes relevant impacts in the bats of the region. Impact to be addressed/ Yes. further investigated and assessed in Impact Assessment Phase?
Impact Phase: Cumulative Phase Impact description: Accumulate of Fatality Detailed description of impact: Fatality of individuals due to collision with turbine blades or barotrauma caused by turbines in the Juno WEF and surrounding renewable energy projects. Extent Duration Intensity Status Significance Probability Confidence Without M M M Negative M M M Mitigation With M M L Negative M M M Mitigation Can the impact be reversed? No, as any fatalities would be considered as a loss to the community. Will impact cause irreplaceable Yes, as it could potentially cause local extinctions, if not appropriately loss or resources? managed. Can impact be avoided, Yes. The impact can be avoided to the maximum extent possible with managed or mitigated? the correct avoidance & mitigation measures, as listed below. Mitigation measures: Avoidance of turbines installation in highly sensitive areas for bats; A monitoring plan is recommended during operation phase and, if high levels of mortality are observed during operational phase, management actions should be put into action to mitigate fatality; It is recommended that no tall vegetation should be allowed within the 200m buffer around the wind turbines to reduce the suitability of the areas for bat foragers; A bat monitoring program should be implemented in order to determine the actual impacts of the wind energy facility on the bat community and evaluate if the presence of other projects causes relevant impacts in the bats of the region. Impact to be addressed/ Yes. further investigated and assessed in Impact Assessment Phase?
10.5 Summary / Conclusion This preliminary bat impact study allowed to determine the main impacts likely to affect the bat community present within the proposed Juno Wind Energy Facility site and surrounding area. The results of the data collected allowed to determine that the proposed Juno WEF is located within a low sensitivity area for bat communities, though with some specific features of higher sensitivity. These are habitat features that are known to attract bats, such as water bodies / reservoirs, trees and potential roosts. This preliminary assessment has therefore identified sensitive areas which should be excluded from turbine placement or associated infrastructure, in an early stage of development. Negative impacts identified for the construction, operation and decommissioning phases of the project are expected to have a general medium significance. A pre-construction bat monitoring programme has been completed in order to validate the predicted impacts and significance of the Juno WEF, as well as to propose appropriate mitigation measures. Further detail on potential impacts and mitigation measures will be supplied in the EIA phase.
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No additional major impacts are foreseen in the bat community at this stage and the project is not considered to likely cause irreplaceable loss of biodiversity and should proceed to the next environmental impact stages. At this stage, with the information available and to our best knowledge, there are no fatal flaws identified for the project apart from the higher sensitivity areas, which should be excluded from development.
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11 FRESHWATER AND WETLANDS ASSESSMENT
11.1 Methodology • A desktop and literature review of the area (WEF and transmission line alternatives) under investigation was conducted to collate as much information as possible prior to any detailed fieldwork. The purpose of the desktop assessment is to rank relevant sites according to their ecological sensitivity and to identify an area of HIGH aquatic ecological risk (to be assessed in the Environmental Risk Assessment) if any. • Relevant literature (e.g. SABIF, PRECIS database, Red Data books, provincial ordinances and conservation plans, etc.) was also consulted. • This information was used to produce a scoping report document that also highlights any potential issues for the project, while providing relevant spatial information for the required map production. • A site visit was conducted to determine the location and extent of any sensitive areas earmarked for each of the project components. This allowed for the finalisation of any layouts or alignments as well as assisting with determining the expected requirements / way forward with regard the WULA process.
For reference the following definitions are as follows: Drainage line: A drainage line is a lower category or order of watercourse that does not have a clearly defined bed or bank. It carries water only during or immediately after periods of heavy rainfall i.e. non-perennial, and riparian vegetation may not be present. Perennial and non-perennial: Perennial systems contain flow or standing water for all or a large proportion of any given year, while non-perennial systems are episodic or ephemeral and thus contains flows for short periods, such as a few hours or days in the case of drainage lines. Riparian: the area of land adjacent to a stream or river that is influenced by stream-induced or related processes. Riparian areas which are saturated or flooded for prolonged periods would be considered wetlands and could be described as riparian wetlands. However, some riparian areas are not wetlands (e.g. an area where alluvium is periodically deposited by a stream during floods but which is well drained). Wetland: land which is transitional between terrestrial and aquatic systems where the water table is usually at or near the surface, or the land is periodically covered with shallow water, and which under normal circumstances supports or would support vegetation typically adapted to life in saturated soil (Water Act 36 of 1998); land where an excess of water is the dominant factor determining the nature of the soil development and the types of plants and animals living at the soil surface (Cowardin et al., 1979). Water course: as per the National Water Act means - (a) a river or spring; (b) a natural channel in which water flows regularly or intermittently; (c) a wetland, lake or dam into which, or from which, water flows; and (d) any collection of water which the Minister may, by notice in the Gazette, declare to be a watercourse, and a reference to a watercourse includes, where relevant, its bed and banks
11.2 Present Ecological State and conservation importance The Present Ecological State of a river represents the extent to which it has changed from the reference or near pristine condition (Category A) towards a highly impacted system where there has been an extensive loss of natural habit and biota, as well as ecosystem functioning (Category E).
The national Present Ecological Score or PES scores have been revised for the country and based on the new models, aspects of functional importance as well as direct and indirect impacts have been included (DWS, 2014). The new PES system also incorporates EI (Ecological Importance) and ES (Ecological Sensitivity) separately as opposed to EIS (Ecological Importance and Sensitivity) in the old model. Although the new model is still heavily centered on rating rivers using broad fish, invertebrate, riparian vegetation and water quality indicators.
The Present Ecological State scores (PES) for the drainage lines and the rivers in the study area were rated as follows (DWS, 2014 – where D = Largely Modified and E= Critically modified): Subquaternary Present Ecological Ecological Importance Ecological Sensitivity Catchment Number State 6629 Olifants D Moderate High 6765 Sandlaagte E Moderate Very High
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It is thus evident that the study area systems, i.e. those adjacent to the WEF site are largely degraded and large-scale impacts are affecting the Saadlaagte River in the catchment (>70% change within 500m of the catchments riverbanks). This was confirmed for several of the affected reaches located near the development footprint.
11.3 Baseline Environment The proposed development occurs within the following catchments within the Western and South Western Coastal Belt Ecoregions both located within the Berg Olifants Water Management Area. G30H – Sandlaaagte F60E – Olifants E33G – Klein / Olifants (Transmission line only)
In terms of the National Freshwater Ecosystems Priority Areas (NFEPA) assessment, all of the watercourses within the site have been assigned a condition score of AB (Nel et al. 2011), indicating that they are largely intact with some biological significance. This is largely due to these catchment’s limited flows. Consequently, these systems do not form part of any Freshwater Ecosystems Priority Areas (Nel et al. 2011).
According to the National Freshwater Ecosystems Priority Area (NFEPA) wetland data, no natural wetland could occur within the WEF portion of the study area. However, several Valley bottom wetlands are associated with the Olifants River floodplain and would need to be spanned by the transmission line.
The remainder of the surrounding waterbodies are artificial or man-made. This was confirmed during the site visit and analysis of the various aerial images as well as the National Wetland Inventory Data being updated by CSIR/ SANBI (currently ver. 5.2).
Figure 11.1 indicates the limited number of watercourses observed within the site. Any activities within these areas or the 32m buffer (or the 1:100 flood line, whichever is the greatest) will require a Water Use license (mostly likely a General Authorisation if all other Section 21 uses are below the GA thresholds). Although it is anticipated that these could all be avoided or spanned (transmission line towers).
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11.4 Assumptions and Limitations In order to obtain a comprehensive understanding of the dynamics of both the flora and fauna of both the aquatic communities within a study site, as well as the status of endemic, rare or threatened species in any area, assessments should always consider investigations at different time scales (across seasons/years) and through replication.
However, due to time constraints these long-term studies are not feasible and are mostly based on instantaneous sampling. This site was assessed after a period of rainfall (16-18 February 2018), while the adjacent farms have been visited during other years and seasons, related to a project assessing the state of wetlands of the Olifants River and estuary. This provides the author of this report as an understanding of the region and the aquatic environment.
It should be emphasised that the information only has reference to the study area as indicated on the accompanying maps. This information cannot be applied to any other area without detailed investigation.
For the purposes of this report it is assumed that any existing roads and tracks within the facility will be upgraded, while the new roads and associated transmission lines can avoid or span the observed water courses. A further assumption is that water will be sourced from a licensed resource and not illegally abstracted from any surrounding water courses, particularly if dust suppression is required.
11.5 Preliminary Assessments The following impacts were not assessed as the factors were not present within the study areas aquatic ecosystems: Loss of aquatic species of special concern, and Wetland loss as no natural wetlands were observed in close proximity to any of the proposed infrastructure (i.e. within 500m of the site or will be avoided by the transmission line). Loss of riparian systems and water courses Impact on riparian systems through the possible increase in surface water runoff on riparian form and function.
The only indirect impacts that could occur and mostly for the transmission line were assessed as follows: Increase in sedimentation and erosion Potential impact on localised surface water quality
11.5.1 Construction and Operational Phase Impacts Impact Phase: Construction and Operational Phase Impact description: Increase in sedimentation and erosion within the development footprint during the construction phase and to a lesser degree the operational phase Extent Duration Intensity Status Significance Probability Confidence Without L M L Negative M H H Mitigation With L L L Negative L L H Mitigation Can the impact be reversed? Yes Will impact cause No irreplaceable loss or resources? Can impact be avoided, Yes managed or mitigated? Mitigation measures: Any stormwater within the site must be handled in a suitable manner, i.e. trap sediments and reduce flow velocities. Residual impacts: During flood events, any unstable banks (eroded areas) and sediment bars (sedimentation downstream) already deposited downstream would be disturbed increasing sediment levels in the water column. However due to low mean annual runoff within the region this is not anticipated due to the nature of the development together with the proposed layout.
11.5.2 Construction Phase Impacts Impact Phase: Construction Phase Impact description: Impact on localized surface water quality mainly during the construction phase.
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During construction and to a limited degree the operational activities, chemical pollutants (hydrocarbons from equipment and vehicles, cleaning fluids, cement powder, wet cement, shutter-oil, etc.) associated with site-clearing machinery and construction activities could be washed downslope via the ephemeral systems. Extent Duration Intensity Status Significance Probability Confidence Without L M L Negative M H H Mitigation With L L L Negative L L H Mitigation Can the impact be reversed? Yes Will impact cause Yes irreplaceable loss or resources? Can impact be avoided, Yes managed or mitigated? Mitigation measures: Strict use and management of all hazardous materials used on site. Strict management of potential sources of pollution (e.g. litter, hydrocarbons from vehicles & machinery, cement during construction, etc.). Containment of all contaminated water by means of careful run-off management on the development site. Strict control over the behaviour of construction workers. Working protocols incorporating pollution control measures (including approved method statements by the contractor) should be clearly set out in the Construction Environmental Management Plan (CEMP) for the project and strictly enforced. Appropriate ablution facilities should be provided for construction workers during construction and on-site staff during the operation of the facility. Residual impacts: During flood events, any unstable banks (eroded areas) and sediment bars (sedimentation downstream) already deposited downstream would be disturbed increasing sediment levels in the water column. However due to low mean annual runoff within the region this is not anticipated due to the nature of the development together with the proposed layout.
11.5.3 Cumulative Phase Impacts Impact Phase: Cumulative Phase Impact description: Overall cumulative impact during the construction and operational phases The surrounding 11 projects within a 35km radius of the site were assessed. Of these potential projects, this report author has been involved in the initial EIA aquatic assessments or has managed / assisted with the Water Use License process for 2 of these projects. The author has also reviewed the outcomes of the remaining projects as part of this EIA or other EIA / WUL applications in the region. All of the projects have indicated that their intention with regards to mitigation is selecting the best possible routes to minimise the local and regional impacts and improving the drainage or hydrological conditions within these rivers so that the cumulative impact would be negligible. However, the worse- case scenario has been assessed below, i.e. only the minimum of mitigation is implemented by the other projects, noting only a small number of projects ever reach the construction phase and that flows within these systems are sporadic. Extent Duration Intensity Status Significance Probability Confidence Without L M L Negative M H H Mitigation With L L L Negative L L H Mitigation Can the impact be reversed? Yes Will impact cause Yes irreplaceable loss or resources? Can impact be avoided, Yes managed or mitigated? Mitigation measures: Improve the current stormwater and energy dissipation features not currently found along the tracks and roads within the region Install properly sized culverts with erosion protection measures at the present road / track crossings
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Residual impacts: During flood events, any unstable banks (eroded areas) and sediment bars (sedimentation downstream) already deposited downstream would be disturbed increasing sediment levels in the water column. However due to low mean annual runoff within the region this is not anticipated due to the nature of the development together with the proposed layout.
Other cumulative impacts are: Downstream erosion and sedimentation of the downstream systems and farming operations during flood events, can cause unstable banks (eroded areas) and sediment bars (sedimentation downstream). However due to low mean annual runoff within the region this is not anticipated due to the nature of the development together with the proposed layout. Possible impact on the remaining catchment due to changes in run-off characteristics in the development site. However due to low mean annual runoff within the region this is not anticipated due to the nature of the development together with the proposed layout.
11.6 Conclusion The proposed layouts for the facility would seem to have no impact on the aquatic environment as all of the proposed structures will avoid the delineated watercourses except for a number of water course crossings for the transmission line. This is also largely dependent on the layouts making use of any existing roads and the current state of the receiving environment.
Thus no aquatic protected or species of special concern (flora) were observed during the site visit. Therefore, based on the site visit the significance of the impacts assessed for the aquatic systems after mitigation would be LOW, and consequently no objection to the development is made. This is assuming that the water resources for construction are carefully selected and managed.
Figure 11.2 further indicates the affected water courses and those that would trigger the need for a Water Use License application (a potential GA) in terms of Section 21 c and i of the National Water Act, should any construction take place within these areas.
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Figure 11.1 Potential wetlands according to the National Wetland Inventory (SANBI, Ver 5.2) in relation to the proposed layout.
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Figure 11.2 The 1:50 000 water courses and existing roads known for the site.
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12 NOISE ASSESSMENT
12.1 Methodology A desk-based search was carried out to identify potential noise-sensitive developments (principally houses) within 2 km of the development, using National Geo-Spatial Information 1:50,000 scale digital mapping and Google Aerial imagery.
12.1.1 Estimation of Noise Levels Construction Phase BS 5228 is the described method for predicting levels of noise during construction.
Operational Phase The IOA Good Practice Guide (GPG), published by the UK Institute of Acoustics (IOA) in May 2013 and has been endorsed by the UK Government as current industry good practice. The guide presents current good practice in the assessment of wind turbine developments at the various stages of the assessment process and is the method used for predicting levels of wind turbine noise at receptors during operation.
12.1.2 Estimation of the Desired Rating Level Construction Phase As effects during the construction phase are temporary in nature, the likelihood of complaint is reduced in comparison to longer-term effects such as operational noise. It is therefore considered appropriate to define the desired rating level for construction noise as 10 dB above the typical district rating levels defined in SANS 10103, i.e.: 55 dBA during the day; and 45 dBA at night.
Operational Phase Based on the guidance provided in SANS 10103, it is considered that appropriate rating levels from noise during operation of the development are 5 dBA above the typical district rating levels, i.e.: 50 dBA during the day; and 40 dBA at night.
12.1.3 Assessment The estimated rating noise levels associated with each phase of the development have been compared with Desired Rating Levels, derived from the guidance in SANS 10103, to determine the likely community response. The following factors have then been assessed: • Extent; • Duration; • Intensity; • Status (positive / negative); • Significance (based on likely community response); • Probability; and • Confidence.
12.2 Baseline Environment
12.2.1 Developments to be included in the investigation During the site visit by a local consultant in March 2018, two areas of interest were identified to establish whether these were inhabited dwellings (shown in Figure 12.1). The location to the west was found to be an agricultural shed, whilst that to the east comprised sheds and a single dilapidated dwelling. It is not currently known whether this building is inhabited, or may be in future, and therefore it has been considered in the assessment as a precautionary approach. The dilapidated dwelling is approximately 700 m from the closest turbine in the development.
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Figure 12.1 Potential sensitive receptor and noise contours.
12.2.2 Developments to be excluded in the investigation The local consultant further identified a cluster of small cabins, around 5 km to the north of the development, close to the grid connection route. As these appear to be used for informal recreation only, and as powerline noise is not considered in this assessment, this development has been excluded. Similarly, the powerline route passes through a residential area at its northern end. As transmission line noise is not considered in this assessment, these developments have been excluded.
12.3 Assumptions and Limitations
12.3.1 Estimation of the expected rating level Construction Phase For each phase of construction, relevant items of plant have been determined from experience of similar developments and their noise emission levels taken from the source level tables contained within BS 5228. This has been used to calculate overall noise levels for each activity at a reference distance of 10 m, as follows: Construction of tracks and hardstanding: 92 dBA Excavation and concreting of turbine foundations: 88 dBA Turbine Erection: 86 dBA Generator: 66 dBA Construction noise levels at the identified noise-sensitive development have been calculated as follows: Daytime: Construction of tracks and hardstanding: 49 dBA Excavation and concreting of turbine foundations: 46 dBA Turbine Erection: 44 dBA Night-time: Generator: 22 dBA
Operational Phase
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The predicted maximum operational noise level from the development at the identified potential noise- sensitive development is approximately 45 dBA.
Decommissioning Phase Noise sources during decommissioning would be similar to, though fewer than, those during construction and the duration shorter. Effects during decommissioning would therefore be no greater than those during construction.
12.4 Preliminary Assessments
12.4.1 Construction Phase Impacts
Impact Phase: Construction Phase
Impact description: Construction Noise Noise from equipment and vehicles used during construction of the development. Extent Duration Intensity Status Significance Probability Confidence
Without L L L Neutral L L H Mitigation With L L L Neutral L L H Mitigation Can the impact be reversed? Yes, construction period is temporary. Will impact cause irreplaceable No, construction period is temporary. loss of resources? Can impact be avoided, Yes, through application of good practice during construction. managed or mitigated? Mitigation measures: Construction activities shall be limited to agreed times; Deliveries of turbine components, plant and materials by HGV to site shall only take place by designated routes and within agreed times; The site contractors shall be required to employ the best practicable means of reducing noise emissions from plant, machinery and construction activities; Where practicable, the work programme will be phased; Where necessary and practicable, noise from fixed plant and equipment will be contained within suitable acoustic enclosures or behind acoustic screens; All sub-contractors appointed by the main contractor will be formally and legally obliged, and required through contract, to comply with all environmental noise conditions; Where practicable, night time working will not be carried out; Local residents shall be notified in advance of any night-time construction activities likely to generate significant noise levels, e.g., turbine erection; and Any plant and equipment normally required for operation at night (23:00 - 07:00), e.g., generators or dewatering pumps, shall be silenced or suitably shielded to ensure that the night-time lower threshold of 45 dBA shall not be exceeded at the nearest noise-sensitive receptors. Impact to be addressed/ further No, impacts are not significant and can be satisfactorily investigated and assessed in Impact mitigated. Assessment Phase?
12.4.2 Operational Phase Impacts
Impact Phase: Operational Phase
Impact description: Operational Noise (Day) The maximum operational noise level from the development has been estimated to be 45 dBA at the closest identified potential noise-sensitive development. It is not known with certainty whether this property is inhabited. Extent Duration Intensity Status Significance Probability Confidence
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Without L H L Neutral L L H Mitigation With L H L Neutral L L H Mitigation Can the impact be reversed? Yes, operational noise will cease when the development is decommissioned. Will impact cause irreplaceable No, operational noise will cease when the development is loss of resources? decommissioned. Can impact be avoided, Yes, noise emission from the wind turbines could be reduced, however managed or mitigated? this is not necessary in respect of this impact. Mitigation measures: Not required Impact to be addressed/ further Yes, further investigation is required to establish the status of investigated and assessed in Impact the identified potential noise-sensitive development with Assessment Phase? greater certainty.
Impact Phase: Operational Phase
Impact description: Operational Noise (Night) The maximum operational noise level from the development has been estimated to be 45 dBA at the closest identified potential noise-sensitive development. Extent Duration Intensity Status Significance Probability Confidence
Without L H M Negative M M H Mitigation With L H L Neutral L L H Mitigation Can the impact be reversed? Yes, operational noise will cease when the development is decommissioned. Will impact cause irreplaceable No, operational noise will cease when the development is loss of resources? decommissioned. Can impact be avoided, Yes, noise emission from the wind turbines could be reduced, through managed or mitigated? the measures detailed below. Mitigation measures: Confirm status of potential noise-sensitive development Reduce noise emissions from turbines through the use of reduced-noise operational modes Reduce number of turbines Increase separation between turbines and potential noise-sensitive development Impact to be addressed/ further Yes, further investigation is required to establish the status of investigated and assessed in Impact the identified potential noise-sensitive development with Assessment Phase? greater certainty.
12.4.3 Decommissioning Phase Impacts
Impact Phase: Decommissioning Phase
Potential impact description: Decommissioning Noise Impacts during decommissioning will be similar to those during construction, but are likely to be reduced in magnitude and duration. Extent Duration Intensity Status Significance Probability Confidence
Without L L L Neutral L L H Mitigation
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With L L L Neutral L L H Mitigation Can the impact be reversed? Yes, decommissioning period is temporary. Will impact cause irreplaceable No, decommissioning period is temporary. loss of resources? Can impact be avoided, Yes, through application of good practice during decommissioning. managed or mitigated? Mitigation measures: Decommissioning activities shall be limited to agreed times; Delivery / removal of turbine components, plant and materials by HGV to Site shall only take place by designated routes and within times agreed; The site contractors shall be required to employ the best practicable means of reducing noise emissions from plant, machinery and construction activities; Where practicable, the work programme will be phased; Where necessary and practicable, noise from fixed plant and equipment will be contained within suitable acoustic enclosures or behind acoustic screens; All sub-contractors appointed by the main contractor will be formally and legally obliged, and required through contract, to comply with all environmental noise conditions; Where practicable, night time working will not be carried out. Local residents shall be notified in advance of any night-time decommissioning activities likely to generate significant noise levels, e.g., turbine erection; and Any plant and equipment normally required for operation at night (23:00 - 07:00), e.g., generators, shall be silenced or suitably shielded to ensure that the night-time lower threshold of 45 dBA shall not be exceeded at the nearest noise-sensitive receptors. Impact to be addressed/ further No, impacts are not significant and can be satisfactorily investigated and assessed in Impact mitigated. Assessment Phase?
12.4.4 Cumulative Phase Impacts On the basis that SANS 10328 recommends assessment of the noise effects of an individual wind energy development where it is to be constructed within 2 km of a noise-sensitive development, it is considered that a cumulative effects assessment is required where: Another wind energy development is to be constructed within 4 km of the development; and A noise-sensitive area is present within 2 km of either wind energy development.
Cumulative effects are therefore not considered to require assessment.
12.5 Summary / Conclusion The significance of noise effects has been assessed as: Low during construction and decommissioning; Low during day-time operation; Medium during night-time operation without mitigation; and Low during night-time operation with mitigation.
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13 LANDSCAPE AND VISUAL ASSESSMENT
13.1 Methodology A desktop Scoping Phase Visual Impact Assessment (VIA) was undertaken. This VIA was undertaken in accordance with the Guideline for Involving Visual and Aesthetic Specialists in EIA Processes, as issued by the Western Cape Government’s Department of Environmental Affairs and Development Planning during 2005.
The VIA was undertaken using Geographic Information Systems (GIS) software as a tool to generate a view shed analysis and to apply relevant spatial criteria to the proposed activity. A detailed Digital Elevation Model (DEM) of the region was also created from 20m contour intervals, as issued by the Chief Surveyor-General.
13.1.1 View shed Analysis As a first step of this VIA, a survey was undertaken to determine the existence of significant view corridors associated with the project site. A view corridor is defined as ‘a linear geographic area, usually along movement routes, that is visible to users of the route’ (DEA&DP, 2005). Accordingly, only one dominant view corridor was identified in the region while some secondary corridors are also present. The dominant view corridor is the R362, which is one of primary scenic routes in the municipality and runs from Klawer in the west, north of the Olifants River up to Lutzville, where after the road turns southwards along the sea down to Doringbaai. A further key aspect affecting the potential visual impact of any proposed activity is the topography of the project site and the surrounding environment and the existence of prominent biophysical features from where the project site is visible. The topography and the major ridgelines of the area were subsequently determined and mapped by using a Digital Elevation Model.
13.2 Baseline Environment
13.2.1 Locality The project site is located some 6km east of the town of Strandfontein and approximately 10km north of the town of Doringbaai, and approximately 25km south-west of Vredendal. This area is commonly referred to as the Namaqua West Coast, an area recognised internationally for its iconic beauty and evocative names. The region is mostly known for the yearly wildflower phenomenon which transforms the landscape in a tapestry of colours. The Matzikama Municipality stretches from the Atlantic Ocean in the west to the mountains of the Bokkeveld Escarpment in the east. The Olifants River flows through the southern part of the municipal area, while to the north lay the hilly area known as the Knersvlakte. The natural enclave formed by the Olifants River to the east and north and the Atlantic Ocean to the west is regarded as the Endangered Sand Fynbos Triangle. The project site and future grid connection is located at the interface of the Endangered Sand Fynbos Triangle and the Coastal Corridor.
The subject property is not traversed by any roads. The project site is however accessed via a secondary road located to the south and the west of the project site, which connects to the regional road, R346 located to the west of the project site, leading towards Vredendal. The closest of these roads is the R362 situated approximately 1.7km from the project site. In addition, the Sishen – Saldanha railway line also passes the project site to the west.
13.2.2 Description of the Landscape Character The landscape character of the Namaqualand coastal plan is generally characterised by sandy beaches and rocky headlands vegetated with vulnerable Namakwaland Sandveld. The wider region between the coastal plan and the Olifants River corridor comprises a triangular wedge of sand plain fynbos mainly under dryland farming. This has resulted in this area and vegetation group being accorded Endangered Status by SANBI.
SANPARKS further elaborates on the coastal ecology and describe sand movement corridors as characteristic of the coastal plan landscape. It is mentioned that these corridors forms an integral part of the ecological dynamics of the vegetation and animals that inhabit this landscape. They are regarded as important medium to large scale ecological processes that need to be explicitly considered in conservation plans (https://www.sanparks.org/parks/namaqua/tourism/history.php).
The project site is also located at the interface between the Succulent Karoo and Fynbos Biomes. The Succulent Karoo and the Fynbos Biomes, as part of the Cape Floristic Region are two of the world’s 34
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biodiversity hotspots. The Succulent Karoo bioregion has approximately 6,356 plant species while Namaqualand alone has about 3000 species. Seventeen present are listed as Red Data species (IUCN, 1994). It is estimated that the Succulent Karoo bioregion has about 16% of the world’s succulent plant species. The high level of diversity is a result of a number of factors including: a) Occasional droughts that increase generation turnover and population fragmentation. b) Soil depth, moisture and texture. c) Chemical composition of the bedrock. d) Animal related disturbance regimes (e.g. heuweltjies).
The Succulent Karoo has its own characteristic fauna with the dominant animals being invertebrates, specifically monkey beetles, scorpions, bee flies, bees and masarid and vespid wasps have concentrations of diversity and endemism in the Succulent Karoo Biome. There is a strong faunal relationship between the Succulent Karoo and the Fynbos biome as it is considered a transitional region (https://www.sanparks.org/parks/namaqua/tourism/history.php).
The project site has an evenly sloping terrain and varies in height from about 40m above mean sea level to 170m amsl. The proposed wind turbines are, however, limited to 80-160m amsl. Beyond the project site, the planned powerline evacuation routes cross over the higher-lying Namaqualand Sand Fynbos portions to the east of the project site.
13.3 Assumptions and Limitations This assessment was undertaken during the scoping phase of the project and is based on the information provided by Arcus Environmental Consulting during April and May 2018.
Assessments of this nature generally suffer from a number of defects that must be acknowledged: Limited time: A comprehensive assessment requires a systematic assessment of the environment at different times of the day. Such luxury is not always possible and therefore most assessments are based on observations made at a specific time of day. Educated estimates are made, where applicable, based on the knowledge of the area. With specific reference to the Scoping Phase assessment, it is to be noted that detailed site visits shall be undertaken during the impact assessment phase during which ground-truthing of the expected impacts will also be undertaken. Availability of literature: A thorough assessment requires that all relevant literature on the subject matter is studied, acknowledged and incorporated in the report. Due to a range of factors, forward planning documents are not always available for all spheres of government.
13.4 Preliminary Assessments Based upon the above categorization and the assessment criteria provided in the Guidelines for Involving Visual and Aesthetic Specialists in EIA Processes it is expected that the visual impact of the proposed activity would be classified as ‘high’.
13.4.1 Construction / Operational and Decommissioning (All) Phases Impacts
Impact Phase: All Phases
Potential impact description: Visual impact on the landscape character The sense of place of the wider region is commonly associated with natural resources and intensive and extensive agriculture uses. The sense of place of the region is, to a large degree, intact and the landscape character of the area can be considered to be moderate sensitivity as the landscape only has moderately prominent landforms that could provide some form of enclosure; it has been affected by some man-made features (i.e. existing powerlines); has little inter-visibility with adjacent landscapes; and exhibit a moderate density of sensitive landscape features. Extent Duration Intensity Status Significance Probability Confidence
Without H H M Negative H M M Mitigation With H H L Negative M M M Mitigation
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Can the impact be reversed? No, The scale and nature of the project infrastructure makes it impossible to reverse the expected impact. Will impact cause irreplaceable No, The project will only impact on a relatively small percentage of a loss of resources? wider region with similar characteristics. Can impact be avoided, Partly mitigated, In terms of the landscape and the appearance of managed or mitigated? structures it is to be noted that the turbines are of such a height that there is no actual mitigation other than color schemes, turbine arrangement and minimum flight safety light case to reduce its impact. Other mitigation measures can, however, be implemented to reduce the impact of the ancillary infrastructure. Mitigation measures: Remove/relocate the turbines located in the buffer area, as identified in the Matzikama Municipality Spatial Development Framework. Keep disturbed areas (i.e. roads, footprint and laydown areas) to a minimum. New road construction must be kept to a minimum. Utilise existing roads and tracks to the extent possible. Roads should maintain rural appearance and feel (i.e. two-track path). No hardened road surfaces to be established. No clearing of land to take place outside the demarcated footprints (bar the access roads). The contractor should maintain good housekeeping on site to avoid litter and minimize waste. Impact to be addressed/ further Yes, investigated and assessed in Impact The severity of the potential visual impact be assessed in Assessment Phase? further detail in the EIA phase. Additional spatial analyses must be undertaken in order to create a visual impact index that will further aid in determining potential visual impact. Specific spatial criteria need to be applied to the visual exposure of the proposed facility in order to successfully determine visual impact and ultimately the significance of the visual impact. Ground truthing of the GIS-generated view shed be undertaken to determine/confirm actual visual impact.
Impact Phase: All Phases
Potential impact description: Visual impact on sensitive receptors in the area Specific viewers (visual receptors) experience different views of the visual resource and value it differently. They will be affected because of alterations to their views due to the proposed activity. The visual receptors are grouped according to their location and significance. Differentiation is made between: a) Tourist-related and areas of cultural significance. b) Motorists along roads. c) Residential Areas and Farmstead. d) Recreational areas. Tourists are regarded as visual receptors of exceptional high sensitivity. Their attention is focused towards the landscape which they essentially utilise for enjoyment purposes and appreciation of the quality of the landscape. Residents of the affected environment are classified as visual receptors of high sensitivity owing to their sustained visual exposure to the proposed development as well as their attentive interest towards their living environment. Motorists are generally classified as visual receptors of low sensitivity due to their momentary view and experience of the proposed development. As a motorist’s speed increases, the sharpness of lateral vision declines and the motorist tends to focus on the line of travel (USDOT, 1981). This adds weight to the assumption that under normal conditions, motorists will show low levels of sensitivity as their attention is focused on the road and their exposure to roadside objects is brief. Motorists on scenic routes will present a higher sensitivity. Their reason for being in the landscape is similar to that of the tourists and they will therefore be categorised as part of the tourist viewer group (Axis Landscape Architects, 2014). Extent Duration Intensity Status Significance Probability Confidence
Without M H M Negative M L M Mitigation
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With H H L Negative L L M Mitigation Can the impact be reversed? No, The scale and nature of the project infrastructure makes it impossible to reverse the expected impact. Will impact cause irreplaceable No, The primary tourist attraction and resource in the region is the loss of resources? Atlantic Ocean and, to a lesser extent, the annual flower blooms. It is expected that users of the nearby roads will use the same with the purpose of reaching their end destination at any of the seaside villages. Views onto the Atlantic Ocean are in a western direction, away from the proposed project. Can impact be avoided, Partly mitigated, In terms of the landscape and the appearance of managed or mitigated? structures it is to be noted that the turbines are of such a height that there is no actual mitigation other than color schemes, turbine arrangement and minimum flight safety light case to reduce its impact. Other mitigation measures can, however, be implemented to reduce the impact of the ancillary infrastructure. Mitigation measures: Remove/relocate the turbines located in the buffer area, as identified in the Matzikama Municipality Spatial Development Framework. Keep disturbed areas (i.e. roads, footprint and laydown areas) to a minimum. New road construction must be kept to a minimum. Utilise existing roads and tracks to the extent possible. Roads should maintain rural appearance and feel (i.e. two-track path). No hardened road surfaces to be established. No clearing of land to take place outside the demarcated footprints (bar the access roads). The contractor should maintain good housekeeping on site to avoid litter and minimize waste. Impact to be addressed/ further Yes, investigated and assessed in Impact The severity of the potential visual impact be assessed in Assessment Phase? further detail in the EIA phase. Additional spatial analyses must be undertaken in order to create a visual impact index that will further aid in determining potential visual impact. Specific spatial criteria need to be applied to the visual exposure of the proposed facility in order to successfully determine visual impact and ultimately the significance of the visual impact. Ground truthing of the GIS-generated view shed be undertaken to determine/confirm actual visual impact.
Impact Phase: All Phases Potential impact description: Visual impact of artificial lighting of the proposed activity The project site has a very low illumination factor. The occurrence of light sources in the vicinity of the project site is strictly confined to individual farmsteads and to the settlement of Strandfontein. A slight sky glow effect is associated with the town of Vredendal. The proposed wind turbines will include a safety light source at the top of the respective nacelles while the associated infrastructure will most likely also have some light sources. Due care needs to be taken in the planning, design and operation of the structures that the site does not contribute to light pollution of the area. Extent Duration Intensity Status Significance Probability Confidence
Without M H M Negative M L M Mitigation With L H L Neutral L L H Mitigation Can the impact be reversed? Yes, By eliminating all light sources the impact could be reversed altogether. Will impact cause irreplaceable No, The project will only impact on a relatively small percentage of a loss of resources? wider region with similar characteristics.
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Can impact be avoided, Yes, By implementing the proposed mitigation measures the impact can managed or mitigated? be avoided. Mitigation measures: Outdoor lighting must be strictly controlled so as to prevent light pollution. Remove security light from the top of nacelles (dependent on aviation control approval). Night lighting must be minimized within requirements of safety and efficiency. All lighting must be installed at downward angles. Sources of light must as far as possible be shielded by physical barriers. Consider the application of motion detectors at the substation to allow the application of lighting only where and when it is required. Only minimum wattage light fixtures must be used. Impact to be addressed/ further Yes, investigated and assessed in Impact The severity of the potential visual impact be assessed in Assessment Phase? further detail in the EIA phase. Additional spatial analyses must be undertaken in order to create a visual impact index that will further aid in determining potential visual impact. Specific spatial criteria need to be applied to the visual exposure of the proposed facility in order to successfully determine visual impact and ultimately the significance of the visual impact. Ground truthing of the GIS-generated view shed be undertaken to determine/confirm actual visual impact.
Impact Phase: All Phases Potential impact description: Visual impact of reflectivity and glare of the structures Glare is an adverse consequence of using large smooth and polished surfaces as a building material. Glare is characterised by alight, often reflected, within the field of vision that is brighter than the surroundings resulting in visual discomfort or impairment. Glare also occurs when the light level of a region is brighter than the level to which the eyes are adapted. The impact of glare source depends on the nature of the receptor, the size of the source relative to the visual field, the position of the source within the visual field and intensity of the source. Glare can pose, at minimum, a nuisance and in other cases can create a safety risk. Areas of particular sensitivity include roads, airports and rail as individuals are guiding vehicles and are required to visually scan their environment without averting their gaze (www.rwdi.com). Extent Duration Intensity Status Significance Probability Confidence
Without M H M Negative M L H Mitigation With L H L Neutral L L H Mitigation Can the impact be reversed? Yes, By implementing the proposed mitigation measures the impact can be reversed. Will impact cause irreplaceable No, The impact will not cause an irreplaceable loss. loss of resources? Can impact be avoided, Yes, By implementing the proposed mitigation measures the impact can managed or mitigated? be avoided. Mitigation measures: Consider installing anti-reflective coating on all glass surfaces to reduce the sunlight that is reflected. Install all steel structures and columns at right angles to the sun. Prevent the use of reflective steel columns and structures in the design of the substation. The steel components within the substation should not be painted but be galvanised and allowed to oxidise naturally over time. The grey colour produced in this process will help to reduce the visual impact. Impact to be addressed/ further Yes, investigated and assessed in Impact The severity of the potential visual impact be assessed in Assessment Phase? further detail in the EIA phase.
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Additional spatial analyses must be undertaken in order to create a visual impact index that will further aid in determining potential visual impact. Specific spatial criteria need to be applied to the visual exposure of the proposed facility in order to successfully determine visual impact and ultimately the significance of the visual impact. Ground truthing of the GIS-generated view shed be undertaken to determine/confirm actual visual impact.
Impact Phase: All Phases Potential impact description: Visual impact of desertification of the landscape. The dangers of desertification are well documented. The lack of continued plant growth, coupled with the periodic flash floods and severe thunderstorms could have dire consequences for any development. Great concern therefore needs to be taken in the construction and especially operation of the wind turbines and associated infrastructure to prevent desertification, erosion and scouring of the landscape. Extent Duration Intensity Status Significance Probability Confidence
Without L H H Negative H M H Mitigation With L H L Neutral L L H Mitigation Can the impact be reversed? Yes, By identifying problem areas timeously and responding with the required remedial actions, the impact can be reversed. Will impact cause irreplaceable No, The underlying Namaqualand Strandveld vegetation of the project loss of resources? site is regarded as Least Threatened and can be rehabilitated over time, as the project site is testament to. Can impact be avoided, Yes, By implementing the proposed mitigation measures the impact can managed or mitigated? be avoided or managed. Mitigation measures: Keep disturbed areas to a minimum. No clearing of land to take place outside the demarcated footprint. Create stormwater channels alongside access roads and divert stormwater in the natural veld at regular intervals along the road. Consider installing rainwater tanks to save all water from building roofs. Install spreaders at the bottom of all downpipes/outlets to prevent scouring of the land. Institute a planting regime once construction has ceased to restore disturbed areas. Impact to be addressed/ further Yes, investigated and assessed in Impact The severity of the potential visual impact be assessed in Assessment Phase? further detail in the EIA phase. Additional spatial analyses must be undertaken in order to create a visual impact index that will further aid in determining potential visual impact. Specific spatial criteria need to be applied to the visual exposure of the proposed facility in order to successfully determine visual impact and ultimately the significance of the visual impact. Ground truthing of the GIS-generated view shed be undertaken to determine/confirm actual visual impact.
13.4.2 Cumulative Impact Phase Impacts Cumulative impacts are defined and will be assessed in the future baseline scenario, i.e. cumulative impact of the proposed development equals the change caused by a proposed development when added to the cumulative baseline. The cumulative baseline includes all other assessed developments. In the cumulative assessment the effect of adding the proposed development to the cumulative baseline is assessed.
Impact Phase: Cumulative Phase
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Potential impact description: The cumulative impact of increased traffic during the construction phase. The sub-region is relatively isolated and primarily served by only one (tarred) road. It is expected that the cumulative impact of an increase in traffic movement would be time crowding while the effect would be direct. It is accepted that the impact would however only be experienced during the construction period. Extent Duration Intensity Status Significance Probability Confidence
Without H L M Negative M M H Mitigation With H L M Negative M M M Mitigation Can the impact be reversed? Yes, It is expected that the cumulative impact will only occur during the construction period. Will impact cause irreplaceable No, The short-term nature of the impact will cause only a temporary loss of resources? disturbance of or impact on the resource. Can impact be avoided, Managed, By implementing the proposed mitigation measures the managed or mitigated? impact could be sufficiently managed. Mitigation measures: Ensure that construction occurs, as far as possible, outside of the major tourist seasons. Compile a traffic management plan to coordinate the traffic movement and identify the ideal construction dates. Impact to be addressed/ further Yes investigated and assessed in Impact Assessment Phase?
Impact Phase: Cumulative Phase Potential impact description: The cumulative impact of construction activities. It is expected that the majority of direct impacts will occur during the construction period. The construction activities on site have the potential to cause unwanted activity in the otherwise rural landscape. The cumulative impact during this phase relates to large, construction vehicles on site, dust pollution, light pollution, etc. The cumulative impact would be space crowding while the effect would be direct. Extent Duration Intensity Status Significance Probability Confidence
Without L L M Negative M M H Mitigation With L L M Negative L M H Mitigation Can the impact be reversed? Yes, It is expected that the cumulative impact will only occur during the construction period. Will impact cause irreplaceable No, The short-term nature of the impact will cause only a temporary loss of resources? disturbance of or impact on the resource. Can impact be avoided, Managed, By implementing the proposed mitigation measures the managed or mitigated? impact could be sufficiently managed. Mitigation measures: Contractors to practice sufficient dust-suppression techniques. No construction activities to be permitted outside of typical business hours. No blasting to occur without prior notice to the neighbouring properties and communities. Prepare a construction phase Environmental Management Plan (EMP). Specific attention to be paid in the EMP on the construction camp which is to be kept neat at all times. Impact to be addressed/ further Yes investigated and assessed in Impact Assessment Phase?
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Impact Phase: Cumulative Phase Potential impact description: The cumulative impact of renewable energy projects in the region. The cumulative baseline, illustrates all renewable energy projects in the wider region. By adding the proposed project to the baseline, the cumulative impact of the project is regarded to be additive and synergistic while the effect is regarded as indirect. Due notice should however be taken of the fact that not all renewable energy projects are wind energy projects and the cumulative impact may therefore be exaggerated. Extent Duration Intensity Status Significance Probability Confidence
Without H H M Negative H M M Mitigation With H H L Negative M M M Mitigation Can the impact be reversed? No, The cumulative impact can only be reversed if the project were to be decommissioned. Will impact cause irreplaceable No, The wider area has been identified as an area where renewable loss of resources? project could be located. Several National and provincial policies also point to the importance of renewable energy generation and that these projects should be located in the most suitable areas, such the sub- region. Can impact be avoided, Managed, By grouping the projects together the cumulative impact can managed or mitigated? be reduced to a specific area. Mitigation measures: Identify the most suitable location for the specific renewable energy type. Group renewable energy projects of the same type together in a geographic area to prevent projects from being scattered across the landscape. Market the sub-region as a destination for renewable energy projects and get tourism companies involved to enhance interest in the area (positive impact). Impact to be addressed/ further Yes investigated and assessed in Impact Assessment Phase?
13.5 Summary / Conclusion The construction of the proposed Juno Wind Energy Facility will have a defined visual impact on its surroundings. In order to successfully determine the exact extent of this impact, the anticipated impact will be assessed during the EIA phase.
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14 CULTURAL HERITAGE, ARCHAEOLOGY, AND PALEONTOLOGY ASSESSMENT
14.1 Methodology
14.1.1 Literature Survey and Information Sources A survey of available literature was carried out to assess the general heritage context into which the development would be set. This literature included published material, unpublished commercial reports and online material, including reports sourced from the South African Heritage Resources Information System (SAHRIS). The 1:50 000 map and historical aerial images were sourced from the Chief Directorate: National Geo-Spatial Information, while CapeFarmMapper was also used for current aerial imagery and cadastral details.
14.1.2 Field Survey The preliminary layout was subjected to a detailed foot survey on 13th and 14th March 2018. This was in late summer, although in this relatively dry part of the country seasonality makes little or no difference to the vegetation cover and hence ground visibility. During the survey the positions of finds were recorded on a hand-held Global Positioning System (GPS) receiver set to the WGS84 datum. Photographs were taken at times in order to capture representative samples of both the affected heritage and the landscape setting of the proposed development. It should be noted that the survey focused strongly on the supplied layout with relatively little work in other areas. However, extra emphasis was placed on looking at more ground in the east (where dunes and deflations were noted to occur) and in the far south (where rocky outcrops along the valley margin were likely to be sensitive).
14.2 Baseline Environment
14.2.1 Archaeological Aspects While the Namaqualand coastline to the north (Dewar 2008; Dewar & Orton 2013; Orton 2012b, 2016a) and Elands Bay to Lamberts Bay area to the south (e.g. Buchanan 1988; Jerardino 2003, 2010, 2012; Orton 2006; Parkington 1988, 1990; Parkington & Porraz 2016) are very well researched, the vicinity of the present study area is very little known. Yates (2003) documented a set of shell sites on a low hill with outcropping bedrock 800 m west of the western boundary of the study area and, although he did not survey there, noted the high probability that archaeological sites might be found along the Sandlaagte River valley which falls within the southern edge of the present study area. The sandy slopes leading northwards towards the Olifants River were found to have very little archaeology on them but close to the river a silcrete outcrop was found to have been extensively quarried by Stone Age people. Just north and south of Doringbaai another survey revealed extensive disturbance of the coastal zone but that many LSA shell scatters and middens were present on the southern of the two headlands at Doringbaai (Webley & Halkett 2016). Halkett (2000) also reported several sites from the same general area. These include shell and artefact scatters that include MSA artefacts as well as a small rock shelter with an LSA midden deposit in it located on the coast 2.5 km south of Strandfontein. Further south of Doringbaai, Halkett and Hart (1995) reported a number of sites with most being relatively ephemeral occurrences. However, a rocky hill with disturbed rock shelters and an extensive artefact scatter over it were recorded 6.5 km southeast of the town while a large but thin shell midden was found 0.6 km from the southern edge of town. They also noted the presence of Pleistocene-aged material on the hardpan around the margins of borrow pits in the area. Midway between Doringbaai and Lambert’s Bay Kaplan (2016) noted the presence of shell scatters and middens along the coast. A little further south, Jerardino et al. (2014) recorded and described a number of sites associated with a rocky outcrop 3.5 km inland. These included shell middens, artefact scatters and rock art sites. The latter included both fine-line tradition and geometric tradition paintings. Interestingly, the latter was present in four sites with the same image (circle/square enclosing vertical lines) painted in each case. On the coast in the same area several shell middens have been sampled and described (Kaplan 1994; Orton 2013). To the north Orton (2013) documented two rock art sites and noted the destruction of a large rock shelter deposit containing human remains on the north bank of the Olifants River. The rock art consisted largely of finger dots and can be ascribed to the geometric tradition (Eastwood & Smith 2005; Smith & Ouzman 2004). Surveys along the coastal cliffs to the north of the Olifants River have revealed many sites of varying age (Halkett 2000; Van Schalkwyk & Wahl 2007), although one survey found no sites at all (Hutten & Fourie 2009). Inland of this area Hart (2007) documented many shell scatters, some of which were clustered around small pans some 3.5 km inland. Further north again, at Brand-se-Baai about 60 km
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northwest of the present study area, deflation hollows in dune fields have revealed a multitude of LSA stone artefact scatters dating throughout the last 6000 years (Orton 2015a, 2015b, 2015c, 2017a). An extremely important observation from this area consists of large numbers of Early Stone Age (ESA) artefacts visible on large areas of exposed hardpan. These scatters included numerous handaxes on a variety of materials and represented a unique opportunity to study this period of the Stone Age (Orton 2017b). In the area north of Vredendal and Lutzville a few surveys have revealed the presence of artefacts associated with heuweltjies. Artefacts are generally found around the eroded bases of heuweltjies but sometimes are also stuck into them (Orton 2011, 2012a). The relationship between human occupation and heuweltjies remains unstudied, although it can be said that most artefacts stuck into the heuweltjies seem to be from the ESA. Also in the southern Knersvlakte, some important LSA and MSA sites have been documented along the Varsche River, some of them associated with limestone outcrops (Mackay et al. 2010; Orton, submitted; Orton et al. 2011; Steele et al. 2016), while ESA material is also known to occur in the area (Orton, personal observation).
14.2.2 Historical Aspects The area tends to have relatively few historical structures with Fransen (2004) only listing one – at Vredendal – in his book dealing largely with structures older than about 100 years. The primary town of the region, Vredendal, only dates back to 1933 with the wine and grape industry only taking off in the area shortly afterwards. Its name relates to the farm on which it was laid out. It became a municipality in 1963. Lutzville is a smaller town but is slightly older, dating to 1923, and is named after its founder Johan Lutz but was laid out on Vlermuisklip. Ebenhaezer is the oldest village in the area having begun as a Rhenish Mission Station in 1831 (Raper n.d.). It was later taken over by the Dutch Reformed Church (Burman 1970). Doringbaai and especially Strandfontein appear to be more recent towns, while the history of Papendorp could not be traced. The agricultural development of the area was only possible after the construction of the Bulshoek Dam which was completed in 1919. Canals built from this dam all the way to Ebenhaezer were completed in 1923 and allowed for the irrigation of huge tracts of land along the margins of the river. Although they were largely unlined at first, from 1952 the authorities began lining them with concrete and adding various improvements to the system as a whole. This canal was a major feat for it includes deep excavations into bedrock in places and long tunnels in others (Burman 1970). Although only a 20th century landscape, the agricultural landscape of the lower Olifants River valley is an important component of local history.
14.3 Assumptions and Limitations The field study was carried out at the surface only and hence any completely buried archaeological sites would not be readily located. Similarly, it is not always possible to determine the depth of archaeological material visible at the surface. The site is very large and largely quite uniform. For these reasons the provided layout was assessed in the field with very little survey carried out away from the layout. An effort was made, however, to examine landscape features identified from aerial imagery as potentially more sensitive. The distribution of sites found is assumed to be representative of the area in general.
14.4 Preliminary Assessments
14.4.1 Impacts to Archaeological Resources Archaeological materials can be present either on or below the surface of the study area. Impacts would be felt during construction when equipment moves around on site and when roads are built and when foundations are excavated. Archaeological sites and artefacts can be damaged and/or destroyed during development activities. None of the archaeological sites within the WEF layout area are deemed to be of great significance which means that the Intensity of impacts would be low with the extent also low. Because archaeological sites are unique, non-renewable and irreplaceable the duration of any impacts is always high. These combine to result in a medium consequence which, together with a low chance of impacts actually occurring (because of the locations of known sites relative to the proposed layout) gives an overall impact significance of low. Because no culturally significant sites are known to occur in the layout area, there are no specific mitigation requirements. Relevant management measures would need to be implemented, however, but the post-mitigation impact significance would remain at the low level. There are no fatal flaws in terms of archaeology. Impact Phase: Construction Phase Impact description: Impacts to archaeological resources
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Archaeological resources on the ground (artefacts, occupation debris) can be damaged and/or destroyed during construction activities. Archaeological resources with visual significance (rock art) can have their visual context altered during all phases of development through the presence of foreign/inappropriate structures in the landscape. Extent Duration Intensity Status Significance Probability Confidence Without L H L Negative L L H Mitigation With L H L Negative L L H Mitigation Can the impact be reversed? No, because archaeological resources are unique and cannot be recreated. Will impact cause Yes, because archaeological resources cannot be recreated. irreplaceable loss or resources? Can impact be avoided, Yes, because development layouts can often be altered to avoid managed or mitigated? important resources or else archaeological mitigation work can be conducted. Contextual impacts to rock art can be reduced by maintaining a suitable buffer area. Mitigation measures: Ensure that necessary archaeological mitigation measures have been implemented prior to the start of construction (none required for the present layout); and Ensure that any archaeological material discovered during the course of the construction phase is immediately reported to HWC or an archaeologist. Impact to be addressed/ Yes, because the layout may change and as yet undiscovered further investigated and archaeological sites may be impacted. assessed in Impact Assessment Phase?
14.4.2 Impacts to Palaeontological Resources Although likely to be sparse, significant palaeontological materials are generally likely to be found beneath the surface of the study area with the cover sands being of low sensitivity and unlikely to contain any significant fossils. Impacts would be felt during construction when deep excavations for turbine and substation foundations are excavated. Palaeontological materials can be damaged and/or destroyed during such development activities. No specialist inputs have been included yet at scoping phase but it is assumed by the present author that significant fossils will be sparsely distributed and relatively unlikely to be impacted. A specialist assessment of palaeontological impacts has been requested by HWC and will be incorporated into the EIA phase heritage report. The intensity of impacts would thus be low with the extent also low. Because palaeontological materials are unique, non-renewable and irreplaceable the duration of any impacts is always high. These combine to result in a medium consequence which, together with a low chance of impacts actually occurring (because of the likely sparse distribution of subsurface fossils) gives an overall impact significance of low. Because no fossils are known to occur in the layout area, there are no specific mitigation requirements. Relevant management measures would need to be implemented, however, but the post-mitigation impact significance would remain at the low level. There are no fatal flaws in terms of palaeontology. Impact Phase: Construction Phase Impact description: Impacts to palaeontological resources Palaeontological resources underground (bones, shells) can be damaged and/or destroyed during construction activities. Extent Duration Intensity Status Significance Probability Confidence Without L H L Negative L L H Mitigation With L H L Negative L L H Mitigation
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Can the impact be reversed? No, because palaeontological resources are unique and cannot be recreated. Will impact cause Yes, because palaeontological resources cannot be recreated. irreplaceable loss or resources? Can impact be avoided, Although they cannot be avoided, impacts can be managed and/or managed or mitigated? mitigated during the construction phase. Mitigation measures: Ensure that necessary palaeontological mitigation measures have been implemented prior to the start of construction (none required for the present layout); and Ensure that any palaeontological material discovered during the course of the construction phase is immediately reported to HWC or a palaeontologist. Impact to be addressed/ Yes, because no specialist assessment has been conducted to date further investigated and and one has been requested by HWC during the scoping phase. assessed in Impact Assessment Phase?
14.4.3 Impacts to Graves Graves can be present anywhere in the study area but the chances are higher in sand dunes which would have been more readily excavated by hand. Graves can be very shallow (maybe 0.2 m below surface or even exposed at the surface if cover sands have been eroded or deflated) and could be impacted during construction when equipment moves around on site and when roads are built and foundations excavated. Graves can be damaged and/or destroyed during development activities. None are known within the study area though and the chances of uncovering graves are always very small. Graves are always deemed to be significant heritage resources, however, so the potential intensity of impacts is regarded as high. The extent would be low. Because graves are unique, non-renewable and irreplaceable the duration of any impacts is always high. These combine to result in a high consequence which, together with a low chance of impacts actually occurring (because of the very low likelihood of uncovering graves) gives an overall impact significance of medium. Because no graves are known to occur in the layout area, there are no specific mitigation requirements. With appropriate management measures in place, however, the post- mitigation impact significance would be low. There are no fatal flaws in terms of graves. Impact Phase: Construction Phase Impact description: Impacts to graves Graves can be damaged and/or destroyed during construction activities. Extent Duration Intensity Status Significance Probability Confidence Without L H H Negative L L H Mitigation With L H H Negative L L H Mitigation Can the impact be reversed? No, because graves are unique and cannot be recreated. Will impact cause No, because graves cannot be recreated. irreplaceable loss or resources? Can impact be avoided, Although they cannot be predicted or avoided, impacts can be managed or mitigated? managed and/or mitigated during the construction phase. Mitigation measures: Ensure that any graves discovered during the course of the construction phase is immediately reported to HWC or an archaeologist. Impact to be addressed/ Yes, because management measures need to be written into the further investigated and EMPr during the EIA phase. assessed in Impact Assessment Phase?
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14.4.4 Impacts to Cultural Landscapes Construction Phase The indirect or contextual impacts to the historical and precolonial cultural landscapes during construction when much activity would be occurring on site. Both are assessed together but with the higher ratings. Impacts to the historical landscape will be of medium intensity due to distance and screening. The precolonial landscape is of generally lower cultural significance due to the content and preservation of the rock art but being very close to the proposed facility it will experience a greater degree of visual intrusion. The intensity of impacts is thus likely to be high. Because of the great distances over which wind turbines are visible in this gently undulating landscape, the extent of impacts to the cultural landscapes is deemed to be medium. The construction phase impacts are expected to be of relatively short duration and this aspect is thus rated to be low. The resulting expected consequence is medium. Because impacts would definitely occur, the probability is high and the overall impact significance is medium. Mitigation measures essentially involve reducing and minimising visual impacts in the landscape, since it is not possible to hide such large structures. With mitigation and management measures in place the intensity would reduce to medium but overall the significance of the impacts would remain at the medium level. Given the medium significance rating and the presence of another WEF in the vicinity – to the north of the Olifants River – the proposed land use is not altogether unacceptable and the impacts to the cultural landscapes are not deemed to be a fatal flaw. Impact Phase: Construction Phase Impact description: Impacts to cultural landscapes The visual integrity of cultural landscapes can be eroded during construction activities. Extent Duration Intensity Status Significance Probability Confidence Without M L H Negative M H H Mitigation With L L M Negative M H H Mitigation Can the impact be reversed? Yes, because the facility can be decommissioned, all equipment removed, and the site rehabilitated. Will impact cause No, because although every landscape is unique in its own ways, irreplaceable loss or the landscape will still be there and can be rehabilitated upon resources? decommissioning of the facility. Can impact be avoided, Although impacts cannot be avoided, they can be managed to a managed or mitigated? degree during the construction phase. Mitigation measures: Minimising the amount of surface that gets disturbed during the construction phase; Ensuring that effective rehabilitation measures are put in place after construction; and Minimising lighting of the facility so as to retain the remote character of the site at night. Impact to be addressed/ Yes, because the layout may change and relevant visual mitigation further investigated and measures need to be incorporated into the EIA Phase heritage assessed in Impact report. Assessment Phase?
Operational Phase The indirect or contextual impacts to the historical and precolonial cultural landscapes during the operation phase are assessed together since they are deemed to be similar. The intensity of the impacts will be less than those expected during the construction phase because they relate purely to the existence of the completed facility in the landscape with only minimal vehicular traffic and with the construction areas having been rehabilitated. Impacts to the cultural landscapes will be of medium intensity. Because of the great distances over which wind turbines are visible in this gently undulating landscape, the extent of impacts to the cultural landscapes is deemed to be medium. The operation phase impacts are expected to be of relatively long duration (but not permanent) because they will continue to apply throughout the lifetime of the facility. With time the facility would also become an ‘acceptable’ component of the cultural landscape as the Eskom Sere Wind Farm to the north has done. This aspect is thus rated to be medium. The resulting expected consequence is medium. Because impacts would definitely occur, the probability is high and the overall impact significance is medium. No particular mitigation measures can be applied
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during the operation phase because the status quo will have been set at the end of construction. The overall significance of impacts would thus remain at the medium level. Given the medium significance rating and the presence of another WEF in the vicinity – to the north of the Olifants River – the proposed land use is not altogether unacceptable and the impacts to the cultural landscapes are not deemed to be a fatal flaw. Impact Phase: Operational Phase Impact description: Impacts to cultural landscapes The visual integrity of cultural landscapes can be eroded during operation. Extent Duration Intensity Status Significance Probability Confidence Without M M M Negative M H H Mitigation With M M M Negative M H H Mitigation Can the impact be reversed? Yes, because the facility can be decommissioned, all equipment removed, and the site rehabilitated. Will impact cause No, because although every landscape is unique in its own ways, irreplaceable loss or the landscape will still be there and can be rehabilitated upon resources? decommissioning of the facility. Can impact be avoided, No, because the turbines are too large to hide and their colour managed or mitigated? cannot be varied. Mitigation measures: None required. Impact to be addressed/ Yes, because this is the phase which would have the longest lasting further investigated and impacts and would have the greatest effect on the decision to assessed in Impact proceed with the project. Assessment Phase?
Decommissioning Phase The indirect or contextual impacts to the historical and precolonial cultural landscapes during the decommissioning phase are also assessed together since they are deemed to be similar, although again for slightly different reasons. The intensity of the impacts will once more increase as many vehicles will be required on site during the decommissioning of the facility and rehabilitation of the land but is moderated by the fact that the turbines will be removed. Impacts to the cultural landscapes are expected to be of medium intensity. Because of the great distances over which wind turbines are visible in this gently undulating landscape, the extent of impacts to the cultural landscapes is deemed to be medium at first but reducing as turbines are removed and the land rehabilitated. The decommissioning phase would not last long, so the duration is rated as low. The resulting expected consequence is medium. Because impacts would definitely occur, the probability is high and the overall impact significance is medium. Mitigation measures should aim to reduce the visual intrusion in the landscape. Because the impact would be incrementally reducing during this phase, the intensity is expected to be low. The overall significance of impacts would remain at the medium level, although this may be somewhat inflated due to the definite probability. There are no fatal flaws. Impact Phase: Decommissioning Phase Impact description: Impacts to cultural landscapes The visual integrity of cultural landscapes can be eroded during decommissioning activities.. Extent Duration Intensity Status Significance Probability Confidence Without M L M Negative M H H Mitigation With L L L Negative M H H Mitigation Can the impact be reversed? Yes, because with decommissioning and removal of all equipment the site can be rehabilitated.
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Will impact cause No, because although every landscape is unique in its own ways, irreplaceable loss or the landscape will still be there and can be rehabilitated upon resources? decommissioning of the facility. Can impact be avoided, Although impacts cannot be avoided, they can be managed to a managed or mitigated? degree during the construction phase. Mitigation measures: Minimising the amount of new surface that gets disturbed during decommissioning; Ensuring that the rehabilitation measures are effectively applied after decommissioning; and Keeping the decommissioning phase as short as possible. Impact to be addressed/ No, because physical impacts to the landscape are expected to be further investigated and within the original disturbance footprint. assessed in Impact Assessment Phase?
14.4.5 Cumulative Phase Impacts Cumulative impacts to Archaeological Resources Archaeological resources appear to be fairly sparse in the vicinity of the study area except in close proximity to rocky outcrops which tend to be avoided during renewable energy developments. The study area is far enough from the coast to not contain shell middens which are generally highly susceptible to impacts. Projects built or planned in the Knersvlakte will likely result in the most archaeological impacts but these impacts would be of low significance owing to the nature of the remains and the ease with which mitigation could be carried out. This means that the cumulative impact significance before mitigation would likely be of medium significance but after mitigation this would reduce to low. Because so little is known about the archaeology in the immediate area, there could, in fact, be minor positive impacts (benefits) if the opportunity to sample archaeological sites in the area arose as a result of development. Impact Phase: Construction Phase Impact description: Impacts to archaeological resources and graves Archaeological resources on the ground (artefacts, occupation debris) can be damaged and/or destroyed during construction activities. Archaeological resources with visual significance (rock art) can have their visual context altered during all phases of development through the presence of foreign/inappropriate structures in the landscape. Extent Duration Intensity Status Significance Probability Confidence Without M H M Negative M H H Mitigation With L H L Negative L H H Mitigation Can the impact be reversed? No, because archaeological resources are unique and cannot be recreated. Will impact cause Yes, because archaeological resources cannot be recreated. irreplaceable loss or resources? Can impact be avoided, Yes, because development layouts can often be altered to avoid managed or mitigated? important resources or else archaeological mitigation work can be conducted. Mitigation measures: Ensure that necessary archaeological mitigation measures have been implemented prior to the start of construction; and Ensure that any archaeological material discovered during the course of the construction phases is immediately reported to HWC or an archaeologist. Impact to be addressed/ Yes, because although cumulative impacts to archaeological further investigated and resources are unlikely to result in highly significant negative
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assessed in Impact impacts, they may in fact provide a benefit if archaeological Assessment Phase? sampling were to take place.
Cumulative Impacts to Palaeontological Resources Significant palaeontological resources are likely to be very sparsely distributed in the study area and its surroundings. Because fossils are sparse this raises the potential significance of each fossil and thus increases the possibility of cumulative impacts occurring should other renewable energy facilities be built in the area. The significance of cumulative impacts without mitigation could be of medium significance but with mitigation this would be reduced to low. Note that, as requested by HWC, a specialist assessment will be included in the EIA Phase heritage report. Impact Phase: Construction Phase Impact description: Impacts to palaeontological resources Fossils can be damaged and/or destroyed during construction activities. Extent Duration Intensity Status Significance Probability Confidence Without L H M Negative M L H Mitigation With L H L Positive L L H Mitigation Can the impact be reversed? No, because palaeontological resources are unique and cannot be recreated. Will impact cause Yes, because palaeontological resources cannot be recreated. irreplaceable loss or resources? Can impact be avoided, Yes, because although it is impossible to locate deeply buried fossils managed or mitigated? prior to the commencement of construction (i.e. cannot be avoided), they can be reported when found, temporarily protected and subsequently assessed and/or collected by a palaeontologist. Mitigation measures: Ensure that the necessary measures are in place for the construction phase including monitoring (if recommended by the specialist) and reporting of chance finds. Impact to be addressed/ Yes, because the potential for cumulative impacts does exist, further investigated and despite, and largely because of, the sparse distribution of important assessed in Impact fossils. Assessment Phase?
Cumulative Impacts to Graves Graves are very seldom encountered during development activities in this area. The majority of graves are likely to be in sand dune contexts, especially close to the coast. Although graves are important, which means the intensity and significance of impacts are high before mitigation, the successful rescue of human remains would reduce the overall significance rating to low after mitigation. This latter rating is also affected by the very low probability of actually impacting graves. Impact Phase: Construction Phase Impact description: Impacts to graves Graves may be damaged or destroyed during construction activities. Extent Duration Intensity Status Significance Probability Confidence Without L H H Negative H L H Mitigation With L H L Negative L L H Mitigation Can the impact be reversed? No, because once a grave is disturbed it can never be recreated as it was.
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Will impact cause Yes, because every human is unique, even after death. irreplaceable loss or resources? Can impact be avoided, Yes, because although impacts cannot be avoided if graves are managed or mitigated? revealed during construction, they can be reported, exhumed and stored in a safe repository. Mitigation measures: Ensure that any graves discovered during construction are immediately protected in situ and reported to HWC and/or an archaeologist for further assessment and exhumation. Impact to be addressed/ Yes, because human remains are deemed to be highly significant further investigated and heritage resources and a procedure needs to be in place for dealing assessed in Impact with them should any be discovered during development. Assessment Phase?
Cumulative Impacts to Cultural Landscapes Impacts to cultural landscapes can vary substantially from place to place and hence from project to project because of the great variability within these landscapes. For this reason, all phases are assessed together here; the operation phase is generally likely to have the most significant impacts, purely because it would last for the longest period of time, and these impacts are reflected below. Because of the high visibility of large structures such as wind turbines, the extent of cumulative impacts is regarded as medium. The intensity can vary dramatically depending on the nature of the cultural landscape being impacted and the proximity of the development to it. Many landscapes proposed to host renewable energy facilities in this area tend to have very limited anthropogenic features. Highly developed landscapes, such as the Olifants River Valley, tend to be located somewhat away from renewable energy developments so the intensity is regarded as being medium. Because mitigation can never hide renewable energy facilities and generally only improves the visual/contextual impacts at the very local level, the significance of impacts is rated as medium before mitigation and medium after mitigation. Impact Phase: All Phases Impact description: Impacts to cultural landscapes Intrusion into the cultural landscape of structures and/or land uses that are either foreign or inappropriate to that landscape. Such structures or land uses result in visual/contextual degradation of the cultural landscape. Extent Duration Intensity Status Significance Probability Confidence Without M M M Negative M H H Mitigation With M M M Negative M H H Mitigation Can the impact be reversed? Yes, with decommissioning and rehabilitation the landscapes can be restored to their former condition. Will impact cause Yes, in the sense that every landscape and every view across those irreplaceable loss or landscapes are unique. There are other areas where similar (but resources? never identical) landscapes occur but one cultural landscapes can never replace another. Can impact be avoided, No, impacts to the cultural landscape are generally unavoidable managed or mitigated? because if a renewable energy facility is built then there will be an impact to the cultural landscape. However, impacts can be mitigated to a small degree. Mitigation measures: Minimise the amount of land that gets disturbed; Minimise cut and fill operations which result in increased landscape scarring; Ensure effective rehabilitation; and Follow any other recommended visual mitigation measures.
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Impact to be addressed/ Yes, because human remains are deemed to be highly significant further investigated and heritage resources and a procedure needs to be in place for dealing assessed in Impact with them should any be discovered during development. Assessment Phase?
14.5 Summary / Conclusion Impacts to ground-based archaeology and palaeontology are expected to be minimal and of low significance. The vast majority of the study area is of very low sensitivity and would not require further study. Changes to the layout in the vicinity of the sand dunes, however, may require a follow-up survey since there are two sites in this area that should be avoided if possible (Figure 14.1). The rock art sites within the study area are part of a sensitive landscape. The Olifants River Valley is also a sensitive cultural landscape but is located at some distance from the proposed WEF. Impacts to the cultural landscapes are the only real concerns here but are, to a large degree, outweighed by the sustainable economic and social benefits to be obtained by the proposed WEF construction. Also, impacts to cultural landscapes are potentially reversible with effective rehabilitation. It is thus concluded that the proposed project should proceed to the impact assessment phase.
Figure 14.1 Aerial view of the study area showing the suggested heritage no-go areas. All land within 500 m of the centre of the Sandlaagte (south of white line) should be avoided as well as the two significant archaeological sites each with a minimum 30 m buffer (two white circles).
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15 SOCIO-ECONOMIC ASSESSMENT
15.1 Methodology The approach to the study is based on the Western Cape Department of Environmental Affairs and Development Planning’s Guidelines for Social Impact Assessment (2007). The Guidelines are based on accepted international best practice guidelines. The scoping level study involved: A review of socio-economic data; A review of relevant planning and policy frameworks for the area; A review of information from similar studies; and A literature review of social issues associated with wind energy facilities.
The identification of potential social issues associated with the proposed WEF is based on a review of relevant documentation and experience with similar projects in South Africa. This SIA is based on the findings of the SIA undertaken for the previous WF proposed for the site and the author’s experience with renewable energy projects, including wind energy projects. A detailed assessment of the issues will be undertaken during the assessment phase of the EIA.
15.2 Baseline Environment
15.2.1 Legislative and Policy Context Legislation and policy embody and reflect key societal norms, values and developmental goals. The legislative and policy context therefore plays an important role in identifying, assessing and evaluating the significance of potential social impacts associated with any given proposed development. In this regard, assessment of “planning fit” conforms to international best practice for conducting SIAs.
For the purposes of meeting the objectives of the SIA the following national, provincial and local level policy and planning documents were reviewed, namely:
National National Energy Act (2008); White Paper on the Energy Policy of the Republic of South Africa (December 1998); White Paper on Renewable Energy (November 2003); Integrated Resource Plan (IRP) for South Africa (2010-2030); The National Development Plan (2011); New Growth Path Framework (2010); National Infrastructure Plan (2012).
Provincial and local White Paper on Sustainable Energy for the Western Cape Province (2010); The Western Cape Provincial Strategic Plan 2014-2019 (2014); The Western Cape Land Use Planning Act, 2014; The Western Cape Provincial Spatial Development Framework (2014 Revision); The Western Cape Climate Change Response Strategy (2014); The Western Cape Infrastructure Framework (2013); The Western Cape Green Economy Strategy Framework (2013); The One Cape 2040 Strategy (2012); The Western Cape Amended Zoning Scheme Regulations for Commercial Renewable Energy Facilities (2011); The Western Cape Draft Strategic Plan (2010); The Strategic Initiative to Introduce Commercial Land Based Wind Energy Development to the Western Cape – Towards a Regional Methodology (2006); The Guidelines for the Management of Development on Mountains, Hills and Ridges in the Western Cape (2002); West Coast District Municipality Integrated Development Plan (2015/2016 Review); West Coast District Municipality Spatial Development Framework (2014); Matzikama Municipality Spatial Development Framework (2014); Matzikama Municipality Integrated Development Plan (2012-2017).
The findings of the review indicate that renewable energy is strongly supported at a national, provincial and local level. The development of and investment in renewable energy is supported by the National Development Plan (NDP), New Growth Path Framework and National Infrastructure Plan, which all make
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reference to renewable energy. At a provincial level the development of renewable energy is supported by the Western Cape Provincial Strategic Plan, Western Cape Provincial Spatial Development Framework (SDF), West Coast District Municipality Integrated Development Plan (IDP) and SDF and the Matzikama Municipality IDP and SDF.
15.2.2 Administrative Context The proposed Juno WF is located within the Matzikama Local Municipality (MLM), a Category-B Municipality , which is one of five LM that make up the West Coast District Municipality (WCDM) (DC1), a Category-C municipality, within the Western Cape Province. The MLM is bordered in the west by the Atlantic Ocean, in the south by the Saldanha Bay Local Municipality, the Swartland Municipality to the east and the North Cape Province to the north.
The administrative seat of the MLM is Vredendal. As of May 2011 the previous district managed area to the north of the MLM was incorporated into the MLM area. As a result the geographical area of the Municipality increased from roughly 8 000 km2 to slightly less than 13 000 km2. The municipal area comprises 17 towns and or villages that are divided into 8 wards. The towns and villages include Doring Bay, Strandfontein, Papendorp, Ebenaeser, Lutzville-West, Lutzville, Koekenaap, Vredendal, Klawer, Vanrhynsdorp, Nuwerus, Bitterfontein, Kliprand, Put-se-Kloof, Rietpoort, Molsvlei and Stofkraal.
15.2.3 West Coast Municipality Demographic overview of the study area
Population As indicated in Table 15.1 below, the population of the West Coast District Municipality (WCDM) increased by from 282 672 in 2001 to 391 766 in 2011, which represents a significant increase of ~ 38.5%. The population of the Matzikama Local Municipality (MLM) increased from 54 199 in 2001 to 67 147 in 2011, and increase of 24.0 % over the same period. This represents an average annual increase of ~ 3.26 % and 2.14 % for the WCDM and MLM respectively. The increase in the population in both the WCDM and MLM was largely linked to an increase in the economically active 15-65 and +65 year age group. The increase in the economically active 15-65 age group in also reflected in the decrease in the dependency ratios in both the WCDM and MLM (see below). It also reflects an influx of job-seekers to the area. As expected, the number of households in both the WCDM and MLM increased between 2001 and 2011. The size of the household sizes in the WCDM decreased marginally, from 3.5 to 3.4, while in the MLM the size remained the same, namely 3.4.
The majority of the population in the MLM was Coloured (74.7%), followed by Whites (14.8%) and Black Africans (8.5%) (Census, 2011). The dominant language within the Municipality was Afrikaans (89.2%), followed by isiXhosa (~3.4%) and English (1.7%) (Census 2011). The population of the MLM is projected to increase to 72 569 in 2018 and 74 049 in 2010 (Socio-economic profile Matzikama Municipality, 2015).
WCDM MLM
ASPECT 2001 2011 2001 2011 Population 282 672 391 766 54 199 67 147 % Population <15 years 28.7 25.5 28.8 26.8 % Population 15-64 66.1 68.5 64.5 66.9 % Population 65+ 5.2 6.0 5.7 6.3 Households 73 449 106 781 15 189 18 835 Household size (average) 3.5 3.4 3.4 3.4 Formal Dwellings % 90.5 % 87.9 % 89.9 % 88.4 % Dependency ratio per 100 (15-64) 51.4 45.9 54.9 49.4 Unemployment rate (official) 13.8 % 14.6 % 16.5 % 14.0 % - % of economically active population Youth unemployment rate (official) 18.1 % 19.9 % 27.0 % 19.3 % - % of economically active population 15- 34 No schooling - % of population 20+ 9.5 % 5.4 % 11.2 % 6.2 % Higher Education - % of population 20+ 7.0 % 8.1 % 6.1 % 6.9 % Matric - % of population 20+ 19.1 % 23.7 % 16.9 % 20.2 % Table 15.1: Overview of key demographic indicators for the WCDM and MLM (Source: Compiled from StatsSA Census 2011 Municipal Fact Sheet)
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The dependency ratio in both the WCDM and MLM decreased from 51.4 to 45.9 and 54.9 to 49.4 respectively. The age dependency ratio is the ratio of dependents, people younger than 15 or older than 64, to the working, age population, those ages 15-64. The increase represents a positive socio-economic improvement, and reflects a decreasing number of people dependent on the economically active 15-64 age group. This decrease is linked to the increase in the percentage of economically active people in both the WCDM and MLM. The dependency ratios in both the WCDM and MLM are higher than the provincial ratio of 45.0. The ratios are however both lower than the national figure of 52.7.
In terms of percentage of formal dwellings, the number of formal dwellings in the WCDM decreased from 90.5% in 2001 to 87.9% in 2011. In the MLM the number of formal dwellings also decreased marginally from 89.9% to 88.4% for the same period. This is likely to reflect the influx of job seekers to the area from areas such as the Eastern Cape Province.
Employment The official unemployment rate in the WCDM increased for the ten year period between 2001 and 2011, from 13.8% to 14.6%. The rate in the MLM decreased from a low 16.5% to 14%. While youth unemployment in WCDM also increased over the same period, it decreased in the MLM. The unemployment and youth unemployment rates in the WCDM and MLM are lower than the provincial figures of 21.6% and 29.0% respectively. Therefore, despite job losses associated with the decline in the role of the fishing sector and the subsequent loss of employment opportunities in this sector, the level of unemployment in the MLM has decreased.
Household income Based on the data from the 2011 Census, 8.2% of the population of the MLM have no formal income, 1.9% earn between 1 and R 4 800, 3.3% earn between R 4 801 and R 9 600 per annum, 17.6% between R 9 601 and 19 600 per annum and 24.7% between R 19 600 and R 38 200 per annum (Census 2011). The poverty income datum for households is linked to the number of household members (Western Cape Provincial Treasury, 2012a - “Definitions”). According to this yardstick, the average poor South African household (5.1 people) requires R1 6371 / month just to subsist, and R3 162 / month to meet the most basic of food and other needs. The City of Cape Town uses a figure of R3500.00 per month. Based on this measure 55.7% of the MLMs population live close to or below the poverty line. The low income levels are a major concern given that an increasing number of individuals and households are likely to be dependent on social grants. The low income levels also result in reduced spending in the local economy and less tax and rates revenue for the district and local municipality.
Education The education levels in both the WCDM and MLM improved between 2001 and 2011, with the percentage of the population over 20 years of age with no schooling in the WCDM decreasing from 9.5% to 5.4%. For the MLM the decrease was from 11.2% to 6.2%. The percentage of the population over the age of 20 with matric also increased in both the WCDM and MLM, from 19.1% to 23.7% in the WCDM and 16.9% to 20.2% in the MLM. The matric pass levels in both the WCDM and MLM are however lower than the provincial average of 28.1%. Despite this it is worth noting that the 2014 matric results for Matzikama improved from 92.0 per cent in 2013 to 93.7 per cent in 2014 – the highest matric pass rate in the Province (Socio-economic profile Matzikama Municipality, 2015).
Municipal service levels
As indicated in Table 15.2 below, the provision of and access to municipal services as measured in terms of flush toilets, weekly refuse removal, piped water and electricity, increased in both the WCDM and MLM for the period 2001 to 2011. As indicated in Table 15.2 there has been significant improvements in the number of households with access to piped water inside their dwellings in both the WCDM and MLM. These improvements also contribute significantly to the overall improvement in the quality of life of the residents of the WCDM and MLM.
WCDM MLM 2001 2011 2001 2011 % households with access to flush toilet 80.8 85.6 63.4 62.1 % households with weekly municipal refuse removal 69.4 76.5 59.1 67.9 % households with piped water inside dwelling 69.1 78.7 63.2 72.1 % households which uses electricity for lighting 88.1 94.4 81.0 88.7
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Table 15.2: Overview of access to basic services in the WCDM and MLM (Source: Compiled from StatsSA Census 2011 Municipal Fact Sheet)
15.3 Assumptions and Limitations Assumptions The identification and initial assessment is based on the author’s experience with renewable energy projects, including wind energy projects. In this regard it is assumed that the key social issues are likely to be similar. However, it should be noted that the comments on the social impacts contained in the Social Scoping Report are preliminary and will be confirmed during the Assessment Phase. Detailed enhancement and mitigation measures will also be identified during the Assessment Phase.
Limitations No site visit was undertaken in preparing the Social Scoping Report. In this regard it is only possible to effectively interact with key stakeholders once they are fully aware of the new project, which is typically once the Scoping Report has been circulated for comment. However, the author has undertaken in the region of 50 SIAs for WFs and is therefore familiar with the social issues associated with the establishment of WFs. A site visit and follow-up interviews with key stakeholders will be undertaken as part of the assessment phase. The assessment of key social issues will also be informed by other key specialist studies, including the Visual Impact Assessment (VIA) and Heritage Impact Assessment (HIA).
15.4 Preliminary Assessments
15.4.1 Construction Phase Impacts Based on the findings of SIAs undertaken for other WEFs in the WCDM the key social impacts are include:
Potential positive impacts Creation of employment and business opportunities, and the opportunity for skills development and on-site training.
Potential negative impacts Impacts associated with the presence of construction workers on site and in the area; Influx of job seekers to the area; Increased safety risk to farmers, risk of stock theft and damage to farm infrastructure associated with presence of construction workers on the site; Increased risk of grass fires; Impact of heavy vehicles, including damage to roads, safety and dust; Impact on farming activities.
Impact Phase: Construction Phase Impact description: Creation of employment and business opportunities during the construction phase Extent Duration Intensity Status Significance Probability Confidence Without M L M Positive M M H Mitigation With H L H Positive M H H Mitigation Can the impact be reversed? Yes, by not implementing the project. Will impact cause irreplaceable No loss or resources? Can impact be avoided, Yes, measures will be provided in the Assessment Report. managed or mitigated? Mitigation measures: Detailed enhancement and mitigation measures will also be identified during the Assessment Phase. Impact to be addressed/ Yes further investigated and
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assessed in Impact Assessment Phase?
Impact Phase: Construction Phase Impact description: Potential impacts on family structures and social networks associated with the presence of construction workers Extent Duration Intensity Status Significance Probability Confidence Without M L M Negative M M H Mitigation With M L L Negative L L H Mitigation Can the impact be reversed? Yes, by not implementing the project. Will impact cause irreplaceable Unlikely at a community level. loss or resources? Can impact be avoided, Yes, measures will be provided in the Assessment Report. managed or mitigated? Mitigation measures: Detailed enhancement and mitigation measures will also be identified during the Assessment Phase. Impact to be addressed/ Yes further investigated and assessed in Impact Assessment Phase?
Impact Phase: Construction Phase Impact description: Potential impacts on family structures, social networks and community services associated with the influx of job seekers Extent Duration Intensity Status Significance Probability Confidence Without M L L Negative L L M Mitigation With M L L Negative L L M Mitigation Can the impact be reversed? Yes, by not implementing the project. Will impact cause irreplaceable Unlikely at a community level. loss or resources? Can impact be avoided, Yes, measures will be provided in the Assessment Report. managed or mitigated? Mitigation measures: Detailed enhancement and mitigation measures will also be identified during the Assessment Phase. Impact to be addressed/ Yes further investigated and assessed in Impact Assessment Phase?
Impact Phase: Construction Phase Impact description: Potential risk to safety of farmers and farm workers, livestock and damage to farm infrastructure associated with the movement of construction workers on and to the site Extent Duration Intensity Status Significance Probability Confidence Without M L M Negative M M H Mitigation
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With M L L Negative L L H Mitigation Can the impact be reversed? Yes, by repairing damage and compensating for stock losses etc. Will impact cause irreplaceable No loss or resources? Can impact be avoided, Yes, measures will be provided in the Assessment Report. managed or mitigated? Mitigation measures: Detailed enhancement and mitigation measures will also be identified during the Assessment Phase. Impact to be addressed/ Yes further investigated and assessed in Impact Assessment Phase?
Impact Phase: Construction Phase Impact description: Potential loss of livestock, crops and houses, damage to farm infrastructure and threat to human life associated with increased incidence of grass fires Extent Duration Intensity Status Significance Probability Confidence Without M L M Negative M M H Mitigation With M L L Negative L L H Mitigation Can the impact be reversed? Yes, by repairing damage and compensating for damages and losses etc. Will impact cause irreplaceable No loss or resources? Can impact be avoided, Yes, measures will be provided in the Assessment Report. managed or mitigated? Mitigation measures: Detailed enhancement and mitigation measures will also be identified during the Assessment Phase. Impact to be addressed/ Yes further investigated and assessed in Impact Assessment Phase?
Impact Phase: Construction Phase Impact description: Potential dust and safety impacts and damage to road surfaces associated with movement of construction related traffic to and from the site Extent Duration Intensity Status Significance Probability Confidence Without M L M Negative M M H Mitigation With M L L Negative L L H Mitigation Can the impact be reversed? Yes, by rehabilitating disturbed areas. Will impact cause irreplaceable No loss or resources? Can impact be avoided, Yes, measures will be provided in the Assessment Report. managed or mitigated?
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Mitigation measures: Detailed enhancement and mitigation measures will also be identified during the Assessment Phase. Impact to be addressed/ Yes further investigated and assessed in Impact Assessment Phase?
Impact Phase: Construction Phase Impact description: The activities associated with the construction phase, such as establishment of access roads and the construction camp, movement of heavy vehicles and preparation of foundations for the WEFs and power lines will damage farmlands and result in a loss of farmlands for grazing. Extent Duration Intensity Status Significance Probability Confidence Without M L M Negative M M H Mitigation With M L L Negative L L H Mitigation Can the impact be reversed? Yes, by rehabilitating disturbed areas. Will impact cause irreplaceable No, however, disturbed areas will need to be rehabilitated. loss or resources? Can impact be avoided, Yes, measures will be provided in the Assessment Report. managed or mitigated? Mitigation measures: Detailed enhancement and mitigation measures will also be identified during the Assessment Phase. Impact to be addressed/ Yes further investigated and assessed in Impact Assessment Phase?
15.4.2 Operational Phase Impacts Based on the findings from of SIAs for other wind energy projects the key social issues affecting the operation phase are likely to include:
Potential positive impacts The establishment of renewable energy infrastructure and generation of clean, renewable energy; Creation of employment and business opportunities. The operation phase will also create opportunities for skills development and training; Generate income for landowners; Benefits associated with the establishment of a Community Trust.
Potential negative impacts The visual impacts and associated impact on sense of place; Impact on property values; and Potential impact on tourism.
Impact Phase: Operational Phase Impact description: Development of infrastructure to generate clean, renewable energy Extent Duration Intensity Status Significance Probability Confidence Without M M M Positive M M H Mitigation With M H M Positive H H H Mitigation
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Can the impact be reversed? Yes, by removing the infrastructure. Will impact cause irreplaceable No loss or resources? Can impact be avoided, Yes, measures will be provided in the Assessment Report. managed or mitigated? Mitigation measures: Detailed enhancement and mitigation measures will also be identified during the Assessment Phase. Impact to be addressed/ Yes further investigated and assessed in Impact Assessment Phase?
Impact Phase: Operational Phase Impact description: Creation of employment and business opportunities associated with the operational phase Extent Duration Intensity Status Significance Probability Confidence Without M M L Positive M M H Mitigation With M M M Positive M H H Mitigation Can the impact be reversed? Yes, by removing the project. Will impact cause irreplaceable No loss or resources? Can impact be avoided, Yes, measures will be provided in the Assessment Report. managed or mitigated? Mitigation measures: Detailed enhancement and mitigation measures will also be identified during the Assessment Phase. Impact to be addressed/ Yes further investigated and assessed in Impact Assessment Phase?
Impact Phase: Operational Phase Impact description: The generation of additional income represents a significant benefit for the local affected farmer(s) and reduces the risks to their livelihoods posed by droughts and fluctuating market prices for sheep and farming inputs, such as feed etc. Extent Duration Intensity Status Significance Probability Confidence Without M M L Positive L L H Mitigation With M M M Positive M H H Mitigation Can the impact be reversed? Yes, by not implementing agreements. Will impact cause irreplaceable No loss or resources? Can impact be avoided, Yes, measures will be provided in the Assessment Report. managed or mitigated? Mitigation measures: Detailed enhancement and mitigation measures will also be identified during the Assessment Phase.
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Impact to be addressed/ Yes further investigated and assessed in Impact Assessment Phase?
Impact Phase: Operational Phase Impact description: Establishment of a community trust funded by revenue generated from the sale of energy. The revenue can be used to fund local community development Extent Duration Intensity Status Significance Probability Confidence Without M H M Positive M L H Mitigation With M H H Positive H H H Mitigation Can the impact be reversed? Yes, by not implementing agreements. Will impact cause irreplaceable No loss or resources? Can impact be avoided, Yes, measures will be provided in the Assessment Report. managed or mitigated? Mitigation measures: Detailed enhancement and mitigation measures will also be identified during the Assessment Phase. Impact to be addressed/ Yes further investigated and assessed in Impact Assessment Phase?
Impact Phase: Operational Phase Impact description: Visual impact associated with the proposed WEF and the potential impact on the areas rural sense of place. Extent Duration Intensity Status Significance Probability Confidence Without M M M Negative M M M Mitigation With M M M-L Negative M M M Mitigation Can the impact be reversed? Yes, by removing turbines. Will impact cause irreplaceable No loss or resources? Can impact be avoided, Yes, measures will be provided in the Assessment Report. managed or mitigated? Mitigation measures: Detailed enhancement and mitigation measures will also be identified during the Assessment Phase. Impact to be addressed/ Yes further investigated and assessed in Impact Assessment Phase?
Impact Phase: Operational Phase Impact description: Potential impact on property values linked to the visual impact associated with the proposed WEF and the potential impact on the areas rural sense of place. Extent Duration Intensity Status Significance Probability Confidence
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Without M M M Negative L L M Mitigation With M M L Negative L L M Mitigation Can the impact be reversed? Yes, by removing turbines. Will impact cause irreplaceable No loss or resources? Can impact be avoided, Yes, measures will be provided in the Assessment Report. managed or mitigated? Mitigation measures: Detailed enhancement and mitigation measures will also be identified during the Assessment Phase. Impact to be addressed/ Yes further investigated and assessed in Impact Assessment Phase?
Impact Phase: Operational Phase Impact description: Potential impact of the WEF on local tourism. Extent Duration Intensity Status Significance Probability Confidence Without M M L Negative L L H Mitigation With M M L Negative L L H Mitigation Can the impact be reversed? Yes, by removing turbines. Will impact cause irreplaceable No loss or resources? Can impact be avoided, Yes, measures will be provided in the Assessment Report. managed or mitigated? Mitigation measures: Detailed enhancement and mitigation measures will also be identified during the Assessment Phase. Impact to be addressed/ Yes further investigated and assessed in Impact Assessment Phase?
15.4.3 Decommissioning Phase Impacts Typically, the major social impacts associated with the decommissioning phase are linked to the loss of jobs and associated income. This has implications for the households who are directly affected, the communities within which they live, and the relevant local authorities. However, in the case of the proposed facility the decommissioning phase is likely to involve the disassembly and replacement of the existing components with more modern technology. This is likely to take place in the 20 - 25 years post commissioning. The decommissioning phase is therefore likely to create additional, construction type jobs, as opposed to the job losses typically associated with decommissioning. The number of people employed during the operational phase of a single 140 MW WF will be in the region of 30. Given the relatively low number of people employed during the operational phase the decommissioning of the facility is unlikely to have a significant negative social impact on the local community. The potential impacts associated with the decommissioning phase can also be effectively managed with the implementation of a retrenchment and downscaling programme. The decommissioning phase will also create employment opportunities. This will represent a positive impact. These jobs will, however, be temporary.
Impact Phase: Operational Phase
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Impact description: Social impacts associated with the decommissioning phase are linked to the loss of jobs and associated income. Extent Duration Intensity Status Significance Probability Confidence Without M M M Negative M M H Mitigation With M L L Negative L L H Mitigation Can the impact be reversed? Yes, by removing turbines. Will impact cause irreplaceable No loss or resources? Can impact be avoided, Yes, measures will be provided in the Assessment Report. managed or mitigated? Mitigation measures: Detailed enhancement and mitigation measures will also be identified during the Assessment Phase. Impact to be addressed/ Yes further investigated and assessed in Impact Assessment Phase?
15.4.4 Cumulative Phase Impacts Impact Phase: Cumulative Phase Impact description: Cumulative visual impact associated with the establishment of a WEF on the areas rural sense of place and character of the landscape. Extent Duration Intensity Status Significance Probability Confidence Without M M M Negative M M H Mitigation With M M M Negative M M H Mitigation Can the impact be reversed? Yes, by removing turbines. Will impact cause irreplaceable No loss or resources? Can impact be avoided, Yes, measures will be provided in the Assessment Report. managed or mitigated? Mitigation measures: Detailed enhancement and mitigation measures will also be identified during the Assessment Phase. Impact to be addressed/ Yes further investigated and assessed in Impact Assessment Phase?
Impact Phase: Cumulative Phase Impact description: The establishment of a number of renewable energy facilities has the potential to place pressure on local services, specifically medical, education and accommodation. Extent Duration Intensity Status Significance Probability Confidence Without M L L Negative L L H Mitigation With M L L Negative L L H Mitigation
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Can the impact be reversed? Yes, by implementing effective mitigation. Will impact cause irreplaceable No loss or resources? Can impact be avoided, Yes, measures will be provided in the Assessment Report. managed or mitigated? Mitigation measures: Detailed enhancement and mitigation measures will also be identified during the Assessment Phase. Impact to be addressed/ Yes further investigated and assessed in Impact Assessment Phase?
Impact Phase: Cumulative Phase Impact description: The establishment of a number of renewable energy facilities in the region will create employment, skills development and training opportunities, creation of downstream business opportunities. Extent Duration Intensity Status Significance Probability Confidence Without M H M Positive M L H Mitigation With M H M Positive H M H Mitigation Can the impact be reversed? Yes, by not implementing the project. Will impact cause irreplaceable No loss or resources? Can impact be avoided, Yes, measures will be provided in the Assessment Report. managed or mitigated? Mitigation measures: Detailed enhancement and mitigation measures will also be identified during the Assessment Phase. Impact to be addressed/ Yes further investigated and assessed in Impact Assessment Phase?
15.4.5 Assessment of No-Development Option South Africa currently relies on coal-powered energy to meet more than 90% of its energy needs. As a result South Africa is one of the highest per capita producers of carbon emissions in the world and Eskom, as an energy utility, has been identified as the world’s second largest producer carbon emissions. The No- Development option would represent a lost opportunity for South Africa to supplement its current energy needs with clean, renewable energy. Given South Africa’s position as one of the highest per capita producer of carbon emissions in the world, this would represent a significant negative social cost.
However, at a provincial and national level, it should be noted that the proposed WEF development is not unique. In this regard, a significant number of other renewable energy developments are currently proposed in the Western Cape and other parts of South Africa. Foregoing the proposed establishment of WFs would therefore not necessarily compromise the development of renewable energy facilities in the Western Cape Province and or South Africa. However, the socio-economic benefits for local communities in the WCDM and MLM would be forfeited.
Impact Phase: No-Development Assessment Impact description: The no-development option would result in the lost opportunity for South Africa to supplement is current energy needs with clean, renewable energy and a lost opportunity for the MLM. Extent Duration Intensity Status Significance Probability Confidence
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Without M H L Negative M M H Mitigation With M H L Positive M M H Mitigation Can the impact be reversed? Yes, by not implementing the project. Will impact cause irreplaceable No loss or resources? Can impact be avoided, Yes, measures will be provided in the Assessment Report. managed or mitigated? Mitigation measures: Detailed enhancement and mitigation measures will also be identified during the Assessment Phase. Impact to be addressed/ Yes further investigated and assessed in Impact Assessment Phase?
15.5 Summary / Conclusion The development of the proposed Juno WEF will create employment and business opportunities for locals during both the construction and operation phases of the project. Based on experience with other WEF projects, the negative impacts associated with the construction phase can be effectively mitigated if the recommended mitigation measures are implemented. Detailed mitigation measures will be outlined in the Social Impact Assessment Report (SIAR). Based on the review of key planning documents that pertain to the study area it is clear that the development of renewable energy (including wind farms) in the West Coast District and MLM is supported. However, the SIA also highlight the need to ensure that the siting of renewable energy facilities (including wind farms) does not impact on the areas tourism potential and scenic assets. The establishment of a Community Trust will also benefit the local community. The proposed development will also represent an investment in clean, renewable energy infrastructure, which, given the negative environmental and socio-economic impacts associated with a coal based energy economy and the challenges created by climate change, represents a significant positive social benefit for society as a whole. A review of the Renewable Energy Independent Power Producers Procurement Programme (REIPPPP) indicates that the programme has resulted in significant socio-economic benefits, both at a national level and at a local, community level. These benefits are linked to foreign Direct Investment, local employment and procurement and investment in local community initiatives. The potential visual and cumulative impact on the areas sense of place and assessment of significance will be informed by the findings of the VIA undertaken for the proposed Juno WF as part of the Assessment Phase of the EIA.
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16 PUBLIC PARTICIPATION Throughout this process, stakeholders have been and will be encouraged to communicate with the PPP team to raise issues, ask questions or make suggestions. Registration of I&APs will continue throughout the process as well.
16.1 Key Stakeholders At this stage of the process, a number of key stakeholders have been identified and included on the project database. These key stakeholders include (but are not limited to) the following: Landowners and Surrounding Landowners; Local Municipality (Matzikama); District Municipality (West Coast); Ratepayers Associations; CapeNature; Olifants River Estuary Advisory Forum; Namaqua West Coast Tourism; ESKOM; Western Cape Department of Environmental Affairs and Development Planning (DEADP); Department of Water and Sanitation (DWS); Birdlife SA; Department of Mineral Resources (DMR); Department of Agriculture, Forestry and Fisheries (DAFF); Heritage Western Cape (HWC); South African National Roads Agency (SANRAL); South African Civil Aviation Authority (SACAA); and Transnet.
16.2 Tasks Undertaken Thus Far Advertisements placed in the relevant local and provincial newspapers (in English and Afrikaans). Site notices were erected on the site boundary, nearby public gathering points and Juno substation where visible to the public. Delivery of written notification to the pre-identified Interested and Affected Parties. Identification of relevant stakeholders and compilation of a project Interested and Affected Party database. A public event was held in order to explain the findings of the Scoping Report, facilitate comment and present to the public what issues shall be investigated during the EIA Phase.
16.3 Synopsis of Key Issues Comments received from the public during the review of the Draft Scoping Report has been collated into a Comments and Responses Trail, which will document the issues raised and provide project team responses to the comments received. A summary of issues raised during the public comment period on the Draft Scoping Report are reflected in Table 16.1 below. Table 16.1 below does not include I&AP correspondence related to communication other than comments received during the DSR public comment period. Complete I&AP correspondence is available under Appendix B6. Minutes of the Public Meeting held at Strandfontein Municipal Hall on 03rd July 2018, during which comments on the DSR were received from I&AP attendees and responded to by the project team, are also not included in Table 16.1 below. The minutes of the Public Meeting are available under Appendix B10.
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Table 16.1: Summary of Issues Raised and Project Team Responses Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received Lyle Martin 25 June Email From: [email protected] From: Juno 2018 [mailto:[email protected]] Sent: Monday, June 25, 2018 9:36 Road Sent: Monday, June 25, 2018 9:09 AM To: '[email protected]' Network To: Juno
Mail from Lyle Martin. Click on the link below to VIEW or REPLY to the mail online....
Mailbox : pgwc.gov.zamailbox?p=21E4729B326C12B7C378DBEFA9A8AB4AB563A002DC51 B30C
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received Email attachment ROAD NETWORK MANAGEMENT Email: [email protected] The Environmental Assessment tel: +27 21 483 4669 Practitioner (EAP) acknowledges the Rrn 335. 9 Dorp Street, Cape Town. 8001 comment received from the Western Cape PO Box 2603. Cape Town, 8000 Road Management Authority received . The Farm Name and Portion is correct for REFERENCE: 16/9/6/1-17/66 (Job 26165) the proposed Juno Wind Energy Facility ENQUIRIES: Ms GO Swanepoel (WEF). Potential impacts on the two Minor DATE: 22 June 2018 Roads affected by the proposed development will be assessed during the Arcus Consultancy Services South Africa Environmental Impact Assessment (EIA) Office 220 Cube Workspace phase Traffic Impact Assessment. Cnr Long Street and Hans Stijdom Road CAPETOWN 8001
Attention: A Bodasing
Dear Sir
REMAINDER OF FARM DE BOOM 273, VANRHYNSDORP: DRAFT SCOPING REPORT FOR JUNO WIND ENERGY FARM: MINOR ROADS 9624 AND 9626
1. Your letter to Interested and Affected Parties dated 7 June 2018 refer. Reference is made to the email entitled ‘Juno WEF EIA - Notification of Availability of Draft Scoping Report’. A copy of this Notification Email is available in Appendix B8 of the Final Scoping report. 2. The application affects Minor Roads 9624 and 9626 for which this Branch is The EAP acknowledges that the Western the Road Authority. Cape Road Authority has jurisdiction over roads affected by the proposed development. Potential impacts on the two Minor Roads affected by the proposed development will be assessed during the EIA phase Traffic Impact Assessment.
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received 3. This Branch offers no objection to the issuing of the Environmental The EAP acknowledges that the Western Authorisation in terms of the National Environmental Management Act. Cape Road Authority has no objection to the issuing of Environmental Authorisation for the proposed Juno WEF. 4. Detailed comment will be provided in terms of traffic and access upon The EAP acknowledges that detailed receipt of the land use application. comment will be provided by the Western Cape Road Authority upon receipt of the land use application. 5. This Branch in terms of the Roads Ordinance 19 of 1976 is not obliged to Maintenance of the Minor Roads affected maintain Minor Roads. by the proposed Juno WEF will be carried out by the developers’ contractors during the construction phase. Yours faithfully The EAP acknowledges the source of the comments as ML Watters or Chief Director: Road Network Management. The EAP also acknowledges the email Endorsements provided, namely Arcus, Matzikama Local Municipality, Ceres District Roads Engineer, West Coast ML WATTERS District Municipality, Mr DO Fortuin and Mr or CHIEF DIRECTOR: ROAD NETWORK MANAGEMENT ML Watters.
ENDORSEMENTS 1. Arcus Consulting Services SA Attention: A Bodasing (e-mail: [email protected])
2. Matzikama Municipality Attention: Mr B Smit (e-mail: [email protected])
3. District Roads Engineer Ceres
4. West Coast District Municipality Attention: Mr Dana van der Westhuizen (e-mail)
5. Mr DO Fortuin (e-mail)
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received 6. Mr ML Watters (e-mail) Lehan 4 July Email From: Lehan Fouche [mailto:[email protected]] From: Juno Fouche 2018 Sent: Wednesday, July 4, 2018 8:33 Sent: Thursday, July 5, 2018 17:17 To: Juno
Thank you for making a presentation at the Public Meeting last night in Dear Lehan Strandfontein and entertaining remarks and questions from the floor during the session. My pleasure for the presentation.
Seeing that the deadline for DSR comments is 9 July and I need to visit Cape Thank you for attending the meeting it Town from this coming Friday to next Wednesday 11 July, I need to obtain the was great to meet you in person. Power Point Presentation, Meeting Minutes and Attendance Register urgently as You should have recently received the requested. Could you also share the contact details and positions of the three public meeting minutes and presentation. AMDA Development officials that attended. Contact details for the AMDA attendees Thank you and regards. are included in the Attendance Register Lehan (attached to the minutes). Further to that Voorsitter please find Piero’s signature below: Strandfontein Belastingbetalersvereniging (SBV) Posbus 222 Piero Granelli Doringbaai CEO 8151 AMDA Developments (Pty) Ltd Sel no’s: 0787430549 (Lehan- Voorsitter) 0832328731 (Kobus- Tesourier) Mobile: +27 82 333 3368 0836306120 (Allen- Sekretaris) Email: [email protected] SBV E-pos: [email protected] a
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received
Please include me in correspondence with AMDA for our EIA reporting requirements.
Thank you Lehan 5 July Email From: Lehan Fouche [mailto:[email protected]] From: Juno Fouche 2018 Sent: Thursday, July 5, 2018 16:53 Sent: Thursday, July 5, 2018 17:34 To: Juno
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received
Voorsitter Strandfontein Belastingbetalersvereniging (SBV) Posbus 222 Doringbaai 8151 Sel no’s: 0787430549 (Lehan- Voorsitter) 0832328731 (Kobus- Tesourier) 0836306120 (Allen- Sekretaris) SBV E-pos: [email protected] Email attachment MEMORANDUM The Environmental Assessment Practitioner (EAP) acknowledges receipt of From: Lehan Fouche Chairperson - Strandfontein Ratepayers Association comments from the Strandfontein (SBV) Ratepayers Association (SBV) Chairman Mr Lehan Fouche. To: Ryan David-Andersen Arcus Consulting
Relevant Officials AMDA Development
Date: 5 July 2018
Subject: Comment on the DSR on the Juno Wind Energy Facility near Strandfontein, Matzikama Municipality Preamble Reference is made to Email Notifications Communications via email and related notices calling for public participation, distributed to Interested and Affected request for comment on the Draft Scoping Report (DSR) on the proposed Juno Parties (I&APs). Copies of all Email Wind Energy Facility and an invitation to a public meeting were received from Notifications are available in Appendix B of Arcus Consulting during the month of June 2018. the Final Scoping Report (FSR). The commenting period for the DSR was set for 30 days from 8 June to 9 July Reference is made of Public Meeting held 2018 and a public meeting was held on 3 July in the Strandfontein Municipal at Strandfontein Municipal Hall on 03rd Community Hall. The public meeting, during which a Power Point Presentation July 2018 from 17:00 - 18:40. There was given by Arcus Consulting, was sadly poorly attended. were eleven attendees in total of which
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received five were representatives of the EAP and developer. The Strandfontein Rate Payers Association (SBV) is well aware of and The Environmental Impact Assessment acknowledges the advantages that renewable energy facilities can bring about (EIA) process aims to identify all potential and are in principle not against such developments, but all the negative impacts expected from the proposed environmental and social impacts/affects and final site location must be fully development. Measures to minimise or considered and wind energy development of this nature justified. mitigate negative impacts and enhance positive impacts are identified as part of the EIA. This impact identification and assessment is conducted by specialists in environmental fields applicable to the project. The Public Participation Process (PPP) is an essential component of the EIA process. The process of public involvement encourages Interested and Affected Parties (I&APs) to contribute their comments and concerns regarding the proposed development during the entire EIA process. In general, the PPP ensures that all issues, underlying concerns and suggestions raised by I&APs are understood, documented and addressed. Confidence is therefore High that all potential negative and or positive environmental and social impacts/affects will be assessed. Mitigation measures to reduce negative impact to sustainable levels and enhance positive impacts will be included in the assessment of the proposed development. The Rate Payers Association (SBV) has a large membership base of permanent The EAP acknowledges that the residents and other property owners of Strandfontein. The SBV is the only Rate Strandfontein Ratepayers Association Payers Association in the Matzikama area that functions successfully and liaises (SBV) as a large and functional ratepayers continuously with its members and the local municipality and participates association participating in the Matzikama quarterly in the Ward 2 Committee of Matzikama. Local Municipality Ward 2 Committee represents a significant portion of the community interested and affected by the
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received proposed Juno Wind Energy Facility (WEF), and welcomes their input into the EIA process for the proposed development. Although reference was made of the Basic Assessment Report on the 16km The Public Participation Process (PPP) for 132KVA powerlines from the proposed site to the Juno Eskom Substation, and the the overhead powerline and the wind report not been made available yet, the SBV cannot provide comment input on energy facility is combined this matter. Mrs Suzanne du Plessis as SBV member and being previously notwithstanding separate application chairperson and currently active member of the Olifant’s River Estuary processes (i.e. Basic Assessment for the Management Committee, has during the meeting, amongst others raised a powerline and Full Scoping and EIA for previous power line assessment matter involving the Juno Substation. Mrs du the WEF). Integration of the PPP for the Plessis will provide her comments to Arcus in due course. two separate application processes was explained in greater detail in the Initial Notification distributed to I&APs on 10th May 2018 (copies of these letters are available in Appendix B). The proposed Juno WEF triggers Activities 1 and 15 of the EIA Regulations 2014 Listing Notice 2 as amended, requiring Full Scoping and EIA while the Grid Connection triggers Activities 11 and 27 of the EIA Regulations 2014 Listing Notice 1 as amended, requiring Basic Assessment. The SBV, as a Registered I&AP for the 132 kV Juno WEF Basic Assessment application process, will receive all relevant public correspondence. PPP for the powerline Basic Assessment will include an invitation to comment on the Basic Assessment Report (BAR) and an invitation to attend a Public Meeting that will be held at the Strandfontein Municipal Hall (date to be decided). Mrs Suzanne du Plessis’s comments were received on the 09th July 2018 and are responded to in this table below.
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received This memorandum is meant to provide preliminary input, comment and raise The EAP acknowledges that the purpose certain concerns on the DSR and comes to a finding about establishing a Wind of the memorandum is to provide Energy Facility in close proximity of Strandfontein. preliminary input to the PPP, comment and raise concerns on the DSR and provide a conclusion regarding development of a WEF in close proximity to Strandfontein. The process of public involvement encourages Interested and Affected Parties (I&APs) to contribute their comments and concerns regarding the proposed development during the entire EIA process. In general, the PPP ensures that all issues, underlying concerns and suggestions raised by I&APs are understood, documented and addressed. Comments The EAP acknowledges the important role The SBV with limited human capacity and financial constraints, has made that the Strandfontein Ratepayers concerted affords during the last 2 years for the upgrading, maintenance and Association has in socioeconomic improvement of Strandfontein, as the “Jewell of the West Coast”. Ongoing liaison upliftment of the local community and the with and inputs to the municipality, Madeliefie Makietie Festival committee and marketing of the town of Strandfontein as self-generated projects have contributed positively to promote and improve the a tourist destination. The EAP further image of Strandfontein. The latest SBV communication to the Municipality was acknowledges the SBV’s input to local comprehensive reports to influence the Revised IDP and the Spatial Development policy and spatial planning documents, Framework (now approved form 1 July) with the intention to further upgrade the the Matzikama Municipality Integrated essential water reservoir security and purification plant, reticulation and sewage Development Plan (IDP) and West Coast pumps/networks and the overall beautification of Strandfontein’s urban District Spatial Development Framework appearance and amongst others, to reinstate the Blue Flag Beach status. (SDF), with the intention to promote favourable development to the benefit of Strandfontein. Of note is that both the updated IDP and SDF are in support of renewable energy developments. The town is mainly a coastal retirement village and a recent 2018 report (2017 The EAP acknowledges the demographics Population Survey of Matzikama by Prof Larry Zietsman) indicates that 85% of the of the coastal town of Strandfontein as permanent residents have an average age of 60 years and older, making them identified during a Community Survey by more vulnerable. Furthermore the town is a popular annual holiday destination Prof Larry Zietsman in 2017 as well as the ‘vulnerable’ nature of this local community
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received for other owners and visitors from all over the country. The permanent residence due to the average age of residents of 60 population has expanded significantly during the last 2-3 years. years or older. The EAP has requested additional assessment on this ‘vulnerable’ community of Strandfontein by the Visual and Social specialists during the Environmental Impact Assessment (EIA) phase. The Visual Specialist will produce an image of the expected view from the town of Strandfontein toward the
Annual popular holiday destination proposed WEF with superimposed wind turbines as part of their EIA phase Visual Impact Assessment. The Social Specialist will interview residents of the town of Strandfontein during their EIA phase Social Impact Assessment to gain insight and representative comment from this vulnerable community.
Our first observation was the poor attendance of the public meeting on 3 July. The EAP acknowledges the concern There were only 6 community members in attendance of which 4 residents from regarding timing of DSR review and the Strandfontein. The main reason being that most property owners (residents, Public Meeting conducted on 03rd July farmers and families) in and outside of Strandfontein were not available due to 2018 at Strandfontein Municipal Hall from the winter holiday period (22 June tot 17 July) and travelling to neighbouring 17:00 - 18:40. Minutes of this meeting countries and even overseas. For the same reason above some SBV management are available under Appendix B10. The committee members were also not available. The next committee meeting is EAP also acknowledges that this Public scheduled for August. However the committee members had access to the DSR Meeting was poorly attended with 6 and have shared their sentiments on the Juno Wind Energy Facility while out of community members present. town. The timing of the DSR review and public meeting is a great concern and will surely impact negatively on the written comments to be received from Throughout the PPP, stakeholders are be interested and affected parties. encouraged to communicate with the EAP to raise issues, ask questions or make suggestions. Communication will be through telephonic means or in written form. All issues will be included into the Comments and Responses Trail, and responded to and addressed by the project team. Registration of I&APs will continue throughout the Scoping & EIA
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received process. Comments on draft reports need to be received within the specified time periods to ensure they can be taken into account within the final documents, and submitted to the DEA within the legislated timeframes. The EAP will facilitate public comment outside of the DSR 30 day public comment period as explained in the response below. During the meeting the Rate Payers advocated the extension of the deadline date The EAP concurs that the request by the of 9 July for written comment. However due to Environmental Legislation Rate Payers for extension of 30 day public prescripts, this request was not entertained. However, assurance was given that comment period deadline of 09th July continuous public participation would take place and further comments will be 2018 was not accepted due to legislative taken into consideration during the whole EIA process. scheduling requirements. Submission of the Application Form and DSR commence statutory timelines. Of importance for the public comment period on the DSR is the legislative requirement of Final Scoping Report submission within 44 days from receipt of Application Form. 30 day public comment ending 09th July 2018 and the incorporation of comments received falls within these 44 days.
Interested and Affected Party comment received after the initial 30 day DSR comment period will be incorporated into the EIA Report. Another 30 day public comment period will be allocated upon distribution of the Draft EIA Report. Comment may also be submitted to the Department of Environmental Affairs after the Final EIA Report submission. Two of the SBV members actively participated during the public meeting. Issues The EAP has requested the Social and concerns on the impacts raised by the SBV are as follows: Specialist to take the new approved The DSR has not taken any cognisance of the new approved (2018) Namaqua– (2018) Namaqua-West Coast Tourism West Coast Tourism Strategy indicating various tourism objectives, initiatives Strategy into account during the EIA
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received and plans for the next 5 years. Developing a wind energy facility near the unique phase Social Impact policy and planning coastal zone would negatively affect tourism as a whole, especialy between the fit assessment. This document was not Olifant’s River Estuary and Doring Bay. This coastal zone is the only safe stretch available at the time of Scoping phase of coast still accessible to the public and where community tourism Social Impact Assessment, March 2018, improvements and new local establishments could be realised and existing thus was not included in the Scoping outdoor nature and recreation facilities/activities (eg hiking, mountain biking, phase policy and planning fit assessment. surfing, angling, etc) further improved. A literature review of the potential impact of wind farms on tourism will be undertaken as part of the EIA phase Social Impact Assessment. The Social Specialist will also interview representatives from the local tourism sector as part of the EIA phase Social Impact Assessment process.
Safe beaches for leisure and recreation activities
Unspoiled cliffs to the south of Strandfontein for hiking and biking already provided
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received The 2014 Municipal Local Economic Development Strategy (LED) for Matzikama The EAP has requested the Social have identified tourism as an important economic sector after agriculture and Specialist to take the 2014 Municipal Local no mention of this can be found in the DSR. The 2018 revised Integrated Economic Development Strategy (LED) Development Plan and Spatial Development Framework of Matzikama (already and the 2018 revised Integrated implemented from 1 July 2018) is not mentioned and have possibly not Development Plan (IDP) and Spatial scrutinised either. Development Framework (SDF) of Matzikama into consideration during the EIA phase Social Impact policy and planning fit assessment. The updated IDP and SDF were released subsequent to the Scoping phase Social Impact Assessment. The proposed site (Farm De Boom) is very close to Strandfontein. This site via Consistency regarding the distance of the an existing minor gravel road is less than 2 km from Strandfontein town entrance proposed Juno WEF from the town of and 5 km from the high water mark. The DSR and some specialist studies have Strandfontein will be ensured throughout different calculations on the distance of the proposed site to Strandfontein. EIA phase. Some study reports say 5 kms, other 6 kms and even 1,5 km, which shows inconsistency and is very discouraging. Distances include: Entrance to proposed site (Farm De Boom) from entrance to Strandfontein (R362) is 1.66 km; High Water Mark to site boundary is 2.55 km; and Strandfontein to Juno WEF (approximate centrepoints) is 7.50 km. The initial 59 (apparently now 53) wind turbines will have a negative visual The number of turbines that make up the impact from the town as well as from the R 362, being the main tar road for proposed 140 MW Juno WEF are local travellers and visitors to the coast and other towns. The high wind dependent on the machine specifications. turbines will also be visible from the pristine coastal cliffs surrounding The two turbine models being considered Strandfontein and the Olifants Estuary. The DSR Report specifically states that by the developer at present are the “the siting of renewable energy facilities (e.g. wind farms) must not impact on Siemens-Gamesa SG 2.6-114 and the SG the areas tourism potential and scenic assets”. A detailed visual perspectives 3.4-132. The former model generates 2.6 map (photo collage) with turbines superimposed would definitely proof the MW of electricity. 53 of the SG 2.6-114 visual impacts from Strandfontein and different coastal locations. turbines would thus be required to meet the 140 MW generation target. The SG 3.4-132 generates 3.4 MW of electricity,
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received thus 41 turbines would be required to achieve the 140 MW target.
The EAP has requested that the Visual Specialist provide a superimposed photographic model of the turbines as may be expected from the entrance to the town of Strandfontein within the Visual Impact Assessment conducted as part of the EIA phase.
Visual impacts on the R 362 and other scenic assets will be assessed as part of the Visual Impact Assessment during the EIA phase. The fitting of red warning lights on top of the turbines, which is legal EAP has requested that the Visual requirement of civil aviation, would definitely create light polution and will Specialist take into consideration the impact on star gazing and the monthly full moon rise on the easterly horizon. potential impact of warning lights on top During the night the negative impact of the nearby wind facility turbines will of turbines. This potential impact will be be far greater as already observed from the R 362 to the current Sere Wind addressed within the Visual Impact Energy Facility. Assessment conducted during the EIA phase, including cumulative visual impact assessment taking into account the operational Sere Wind Energy Facility and light pollution from this facility. It was indicated during the presentation that the proposed site is the The site selection process undertaken by “Preferred Site”. No concrete facts in the DSR substantiate this view and there the developer to identify a suitable site for is no indication what other alternative sites were considered. The developers the proposed Juno WEF is addressed in most probably used the development opportunity after receiving a land offer the FSR under Section 6.2 Site Selection. from the farm owner to utilise the farm. The developers have surely not Criteria assessed in the site selection considered fully the negative impacts on the nearby Strandfontein town and process include environmental constraints, unique coastal surroundings. It was further requested that another site further land use and availability, site access and away (ideally much further north of the Oliphant’s River) be identified, ideally grid connection availability. where mining activities have already impacted on and away from urban developments. Further investigation to identify alternative and suitable sites Evaluation of the potential negative puts a definite onus on the developer and consultants. impacts of the proposed development on the nearby town of Strandfontein forms
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received part of the current Scoping and EIA process. The proposed access gravel road to the site starting at the R 362 intersection A Traffic Impact Assessment will form part leading into Strandfontein will have a severe impact on the said gravel and tar of the EIA phase. The Traffic Specialist roads during the envisage construction phase of two years. The closest 2 study will assess potential impacts of the farmsteads including residential homes in town with permanent families are proposed route during the construction only about 200 meter from the road intersection/access and no mitigating phase, and identify potential and suitable factors will ever mitigate and soften the noise and movement of construction alternatives for construction vehicle access vehicles and workers. Without doubt the envisaged upgrading of the access to the site. gravel road, would damage large portions of the natural and scares vegetation. The endemic Euphorbia schoenlandii and Aloe framesii are Red The EAP has requested the Ecological Data Species, would therefore be threatened and will permanently disappear. Specialist evaluate the potential impact on Refer the relevant photos below. the Red Data Species mentioned (Euphorbia schoenlandii and Aloe framesii) during EIA phase. Search and Rescue of species of conservation concern such as Red Data Species will be required by the Ecological Specialist and Environmental Management Programme to be produced in EIA phase.
Existing farm homesteads 200m from access road
Road intersection into Strandfontein 200m from homes and providing access to site
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Threatened Aloes along access road The gravel access road also crosses over the Sishen Saldanha iron ore line. The EAP has requested the Traffic The bridge width is 9 metres of which only 7.4 metres is road surface because Specialist assess the adequacy of the of water piping on both sides. It is questionable whether the bridge bridge over the Sishen Saldanha railway construction and width are adequate for a loaded and total vehicle mass of for site access use as part of the Traffic 130 000 kg. Further consideration must be given to find an alternative access Impact Assessment to be conducted road site far away from the town entrance and intersection if the envisaged during the EIA phase. Alternative site development is to proceed. access routes will be considered as part of the EIA phase Traffic Impact Assessment.
Bridge over Sishen Saldanha iron ore line showing water piping and narrow road surface
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Because of the close proximity of the site, one of the biggest threats is the The EAP acknowledges the vulnerable negative social impact on the retired and vulnerable residents of nature of the community of Strandfontein. Strandfontein. The town is a safe haven for permanent families, other property The EAP has requested the potential owners and holiday makers visiting annually. Reality and experiences (rather impact of the influx of construction than specialist studies indicating potential impacts and mitigating factors to workers on the town of Strandfontein be lower risks) will clearly demonstrate impacts on safety during the construction further assessed by the Social Specialist in phase of 2 years involving 200 construction workers of various skills. the EIA phase Social Impact Assessment. Construction workers will infiltrate into the town in search for rental accommodation and to buy daily household provisions and croceries. This would change the “sense of place” and the current safe and quite character of the town permanently and would lead to higher crime levels and damages to properties and eventually to assults and even deaths. The neighbouring towns and the already illegal informal settlement under the The EAP has requested the potential Sishen-Saldanha bridge, as well as permanent farm workers and families impact of the influx of construction would also be adversely affected by new construction workers of different workers on the local community to be cultures. Related crime, safety matters and the ever increasing destructive further assessed by the Social Specialist in unrest/mass actions on life and properties are a high reality and would also the EIA phase Social Impact Assessment. put more responsibility on limited Law Enforcement capacity. Law Enforcement already have to deal with ongoing crime, social unstabilities, substance abuse, etc daily. The nearby Juno Wind Energy facility would also impacts negatively and lower Property prices are included in the social farms and residential property values. The Rate Payers Association are very impact assessment as one of the many much concerned about coastal property investments during the construction variables that affect the socio-economic phase and once the facility is operational. Studies suggest that property values environment, however this would not do decrease the closer properties are from wind energy facilities. include a study to the level whereby such impacts would be quantified and monetary compensation be attributed as mitigation.
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received A literature review will be conducted during the EIA phase. Only information from published academic reports, books and peer reviewed journals, will be used (no newspapers, websites, etc.). It should be noted that the literature review is not an impact assessment; it is a presentation of factual information available on an academic research level Properties with views on unique coastal zone worldwide. No relevant literature is available for South Africa as there is no long term data available on the impacts of wind energy facilities on property values in South Africa. As such data will be from studies taken in other wind energy markets where wind energy facilities have been installed and their impacts studied over time. Advocating to reduce the number of wind turbines and push the final location The EAP acknowledges that mitigation thereof further north east on the site, would not adequately address the measures such as reducing the number of associated negative impacts. Whether there are 53 or 40 or even less turbines, turbines or moving the turbines away the adverse effects during the construction phase, the visual appearances of from the coastal town of Strandfontein is turbines from town, scenic coastal cliffs and main routes, the related expected not to address the Strandfontein social/safety aspects and property value concerns for permanent residents and Ratepayers Associations’ concerns of the other property owners would definitely remain. Surely the tourism potential proposed development. and conservation of the coastal areas (mainly from Oliphant’s River Estuary to Doring Bay) and strengthening future local tourism and recreation initiatives The EAP has requested that Visual, would also be adversely impacted upon. Heritage and Social specialists provide input to specific concerns during the EIA phase that fall within their respective fields of study. The Visual Impact Assessment to be conducted during EIA phase will assess the visual impacts of the proposed Juno WEF that may be expected from the town of Strandfontein, the scenic coastal cliffs and the R 362. The Social Impact Assessment will assess the social
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received impacts of the proposed Juno WEF including safety and property value concerns, and the potential impacts on local tourism. Conclusion The EAP acknowledges the Conclusion of Having reviewed the DRS and some of the preliminary specialist studies and comments provided by the Strandfontein after scrutinising the related environmental and social impacts, the Strandfontein Ratepayers Association, that the Rate Payers Association cannot support the establishment of the Juno Wind Association does not support the proposed Energy Facility on the relevant farm, De Boom in close proximity (only 2km) development. from Strandfontein.
Chairperson: Strandfontein Rate Payers Association Date: 5 July 2018 Alana 9 July Email From: Alana Duffell-Canham [mailto:[email protected]] From: Juno Duffell- 2018 Sent: Monday, July 9, 2018 7:33 Sent: Monday, July 9, 2018 15:35 Canham To: Juno
Kind regards, Thank you very much for your comments Alana on the proposed Juno WEF DSR. tel +27 21 866 8000 | fax +27 21 866 1523 | cell +27 082 727 2691 email [email protected] | fax2email +27 86 529 3475 I have forwarded these onto our Client postal Private Bag x5014 Stellenbosch 7599 AMDA. We will address them within the physical Assegaaibosch Nature Reserve Jonkershoek Road Stellenbosch Final Scoping Report and, where www.capenature.co.za additional specialist input is required, as part of the EIA phase.
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received Thank you
Email attachment CAPE NATURE Thank you for your comments Alana. SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599 physical Assegaaibosch Nature Reserve Jonkershoek website www.capenature.co.za enquiries Alana Duffell-Canham telephone +27 21 866 8000 fax +27 21 866 1523 email aduffell- [email protected] reference SSD14/2/6/1/8/3/273_Wind_Juno date 09 July 2018 Ryan David-Anderson Arcus Consultancy Services South Africa Office 220 Cube Workspace Cnr Long Street and Hans Strijdom Road Cape Town 8001
By email: [email protected]
Dear Mr David-Anderson
RE: Proposed Juno Wind Energy Facility, Farm De Boom No. 273, Matzikama Local Municipality – Draft Scoping Report. DEA Ref: TBA CapeNature would like to thank you for the opportunity to comment on the Draft Scoping Report for this application. Thank you for providing a detailed report and specialist studies. Please note that our comments pertain mostly to biodiversity related issues as per our mandate although we do note that there may be other impacts of concern such as visual and sense of place. Terrestrial ecology: The Environmental Assessment 1. The proposed development site is on the remainder of Farm 273 known as Practitioner (EAP) has requested the “De Boom”. Ecological Specialist assess potential The farm is covered predominantly by Namaqualand Strandveld. Although this impacts on these vegetation types during vegetation type is listed as Least Threatened, it has approximately 66% of its the EIA phase and provide impact original extent remaining and notable loss has occurred in the last few years, mitigation measures for inclusion into the
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received mostly due to mining expansion. Namaqualand Strandveld has very little Environmental Management Programme formal protection. Namaqualand Sand Fynbos is also found on the farm. It is (EMPr). currently also listed as Least Threatened but also has very little formal protection. 2. CapeNature and DEA&DP released the Western Cape Biodiversity Spatial Plan The Ecological Specialist will continue to (WCBBSP) in 2017. The WCBSP comprises maps indicating areas of conservation utilise the Western Cape Biodiversity importance (Critical Biodiversity Areas and Ecological Support Areas) as well as a Spatial Plan (2017) during the EIA phase handbook containing landuse guidelines linked to the map categories. This as the dominant conservation planning should be used as a key informant in decision-making processes regarding tool for the proposed site. development and we are pleased to note that the ecological specialist has made reference to the WCBSP in his report. 3. The south-eastern corner of Farm 273 has been determined as Critical Critical Biodiversity Area 1 and the Biodiversity Area (CBA). This mapping largely corresponds with the occurrence Sandlaagte Palaeochannel will retain their of Namaqualand Sand Fynbos which, as mentioned above, has very little formal No-Go Area status throughout the EIA protection. The CBA should be seen as a no-go areas for any turbines as well as process. all related infrastructure (roads, powerlines, cables etc.). The ecological specialist has also identified an area of high botanical sensitivity and importance due to the presence of specialist habitats along the Sandlaagte River and we agree that this area should also be considered as a no-go area for turbines and associated infrastructure. 4. Most of the site has been determined as Ecological Support Area (ESA). The EAP has requested the Ecological Ecological Support Areas can be determined for several reasons. For this site the Specialist address this comment further main reason is to buffer and enhance the protection of the CBAs. Some landuse during EIA phase. Mitigation measures change may be acceptable providing that sufficient habitat remains intact to that promote conservation of ecological ensure that ecological connectivity is not significantly impacted. functioning and connectivity within the ESA will be provided by the Ecological Specialist and in the EMPr. 5. We note that the application is for a maximum of 59 turbines. The number During the EIA phase further constraints and size of the turbines should be determined and finalised as part of the and sensitivite areaswill be identified and environmental impact assessment process. the site layout will be updated further. The final layout with the proposed number of turbines will be submitted in the EIA report. 6. According to the ecological specialist report, fieldwork is stated as being A Botanical Specialist walkthrough and complete. Search and Rescue of Species of Conservation Concern prior to any construction activities will be required by
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received However, micro-siting of turbines may still be required once the number and the EMPr. The report states that prior to layout of the turbines is finalised and this may require additional fieldwork by a construction an ecologist must be botanical specialist. appointed to undertake a walkthrough of the final turbine positions. Avifauna and Bats: The EAP has forwarded this comment to 7. The farm is located fairly close to the Olifants River Estuary Important Bird the Avifaunal Specialist who will take Area (IBA). It is the opinion of the avifaunal specialist that the site is located in cognisance of and address this comment an area of medium to high sensitivity and impacts on avifauna are therefore of within their Avifaunal Impact Assessment concern. The minimum requirements for “Pre-construction” monitoring of during EIA phase. The avifaunal specialist avifauna (according to the latest Bird and Wind Energy Guidelines published by has been monitoring the site in BirdLife South Africa and Endangered Wildlife Trust) should be completed before accordance with the best practice an authorisation is issued. guidelines, the EIA report will include the findings of the required 12 months pre construction bird monitoring. 8. Bat monitoring should also be conducted according to the latest guidelines. One year of Bat Monitoring has been completed for the proposed Juno WEF according to and in compliance with the latest guidelines, at the commencement of monitoring (i.e. Sowler & Stoffberg [2016] South African Good Practice Guidelines for Surveying Bats in Wind Farm Developments – 4th Edition). 9. The adequacy of the suggested buffers must be given more consideration and Environmental Sensitivity Mapping will be justification on in the EIA phase. This is especially important for watercourses undertaken during EIA phase based on and wetlands which is often where both birds and bats conduct most of their specialist input. The EAP will collate all feeding activity. specialist constraints, No-Go Areas, buffer zones and other sensitivities into a single model for the proposed site.
Bird and Bat specialists will provide greater detail in their environmental sensitivity mapping during the EIA phase, relative to Scoping phase. 10. We are pleased to note that cumulative impacts on both birds and bats will Cumulative impact assessment is a be given more consideration in the Environmental Impact Assessment phase of requirement of the EIA Regulations 2014 the application. as amended. All specialists will include in
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received their assessment the potential cumulative impact of the Juno WEF. Aquatic ecology: Internal and access roads will be 11. The aquatic scoping statement states that the assumption has been made evaluated further in EIA phase, in that new roads can avoid or span watercourses. This may not be a correct particular during the Traffic Impact assumption as in our experience some wind energy facilities have needed Assessment. Final internal road layouts to apply for additional authorisations for low-level water crossings as spanning and upgrades will also be assessed during or avoiding was not feasible. The exact location of all roads and crossings must EIA phase. be determined as part of the EIA process. A map should be provided which indicates which existing roads will be upgraded and where additional roads will A map showing existing internal and be constructed (and the total footprint). Although the powerline application may access roads to be upgraded and need to be a separate process, route alternatives should also be assessed as proposed new internal and access roads part of this process to determine the preferred route and in particular the will be provided as part of the EIA phase. watercourse crossing sites. This has relevance to avifauna as well, as sites where powerlines cross watercourses frequently have the highest collision Powerline route alternatives provided in incidences. the DSR are to be updated during EIA phase and will undergo impact assessment as part of the separate Basic Assessment application process. An Avifaunal Specialist Impact Assessment will be conducted as part of this Basic Assessment process for the overhead powerlines route alternatives. 12. We note that the PES of watercourses and wetlands will be further This is correct. investigated in the next phase of the impact assessment process. CapeNature will provide additional comment during the next phase of the EIA Noted thank you. process.
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received. Yours sincerely
Alana Duffell-Canham For: Manager (Scientific Services)
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received Doretha 9 July Email From: Doretha Kotze [mailto:[email protected]] From: Juno Kotze 2018 Sent: Monday, July 9, 2018 11:30 Sent: Monday, July 9, 2018 15:39 To: Juno
Thank you 1. Your letter dated 7 June 2018 and the Draft Scoping Report for the proposal The EAP acknowledges reference to the refer. Draft Scoping Report (DSR) distribution email available in Appendix B. 2. The West Coast District Municipality supports renewable energy facilities, The support of the West Coast District provided these are appropriately located. The West Coast District Municipality for renewable energy Municipality’s comments are informed by the Western Cape Department of developments is acknowledged. Environmental Affairs and Development Planning’s 2010 Draft Strategic Environmental Assessment of Wind Farms in the Western Cape (DSEA). 3. On the DSEA Composite Map Farm 273 is indicated as Negotiable, indicating Mitigation measures will be provided by that with the necessary mitigation measures, the area may be suitable for the specialists for the proposed Juno WEF. wind energy facility purposes. Wind resource data gathered by the applicant has confirmed that this site has suitable wind resource for the development of a 140 MW WEF. 4. The proposal may have adverse visual impacts on the scenic coastal road The Environmental Assessment and the village of Strandfontein necessitating the inclusion of photo Practitioner (EAP) has requested that a montages in the Visual Impact Assessment. photo montage superimposing expected views of wind turbines from the village of
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received Strandfontein be compiled as part the Environmental impact Assessment (EIA) phase Visual Impact Assessment. 5. Attention should be given to the following during the Environmental Impact Consideration of noise impacts, dust Assessment Phase of the project: control measures, storage and disposal of waste and provision of ablution facilities 5.1 Noise impacts on the receiving environment during the construction and will be included as part of the EIA phase operational phases. within the Environmental Management 5.2 Dust control measures during the construction phase. Programme (EMPr). 5.3 Storage and disposal of general and hazardous waste during all phases. 5.4 The provision of ablution facilities during the construction and operational phases. 6. Your attention is drawn to the Matzikama Municipal Land Use Planning Bylaw The applicant will submit the relevant land in terms of which a land use application must be lodged to Matzikama use application for the change in land use Municipality prior to any development taking place. prior to commencement of any development. Proof of this application will be submitted to the relevant parties once finalized. Regards Signature and contact details D o r e t h a K o t z e acknowledged. Stads- en Streekbeplanner/Town and Regional Planner Weskus Distriksmunisipaliteit Langstraat 58 Long Street Posbus 242 PO Box MOORREESBURG 7310 Tel: 022 433 8523 West Coast District Municipality Suzanne du 9 July Email From: du plessis [mailto:[email protected]] From: Juno Plessis 2018 Sent: Monday, July 9, 2018 13:29 Sent: Monday, July 9, 2018 15:49 To: Juno
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received Thank you for holding a public meeting at the Strandfontein Hall in the Matzikama on the 3 July 2018. From: du plessis [mailto:[email protected]] On your list of Interested and Affected Parties please to include: Sent: Monday, July 9, 2018 15:48 Dale Wright - BirdLife SA To: Juno
Do you perhaps have their contact details (email preferable) for me please?
Thank you Suzanne
Email attachment Comments on the Meeting held 3.07.2018 at Strandfontein Hall for: Minutes of the Public Meeting held at Strandfontein Municipal Hall on 03rd July Presentation of DSR (Draft Scoping Report) for the Proposed Juno Wind Turbine 2018 hold reference (Appendix B10). Energy Facility in Strandfontein of the Matzikama Municipality.
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received I am commenting as a South African citizen, member of the SBV and the Olifants Advisory Committee. My questions and comments tabled: Mr Johan Mathee from Lower Olifants River Water User Association (LORWUA) - Would there be overhead Power lines or cables laid underground to the has been added as Interested and substation? Affected Party for the proposed Juno Wind Arcus Consultants informed us, that there is an application for an overhead Energy Facility (WEF) and associated Power Line that was presented for the first time at the meeting so this infrastructure Public Participation Process application would run concurrently. (PPP). Powerlines will be buried were That often creates confusion with the PPP (Public Participation Process). technically feasible. It is unlikely that the I am opposed to the power lines running over the Olifants River. The footprint 132 kV powerline to connect the WEF to becomes far larger of this application than originally presented in the Scoping the national grid can be laid underground. Report. Mr Mathee from LORWUA needs to be an I&AP to give comment. An integrated PPP is being undertaken for the WEF and the overhead powerline due to the interrelated nature of the two separate application processes - essentially one project that is divided into two applications, a Full Scoping and Environmental Impact Assessment (EIA) for the WEF and a Basic Assessment for the Grid Connection.
The Initial notification sent out to I&APs indicated that there will be two separate application process but a combined public participation process, due to the timing of the Basic Assessment process for the grid connection. The Basic Assessment report and details of the grid connection and the specialist studies is still to be provided. All registered I&APs will be notified of this and given the opportunity to review and comment on this report. The information given thus far is to ensure that I&APs are aware that this report is still forthcoming.
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received - Could cables be laid underground? No only between Turbines. Impact Assessment of the overhead Therefore your boundary of area is far larger for the negative impact on the avi- powerlines will be conducted in a separate fauna of this area and site that was presented. Basic Assessment application process. An Avifaunal Impact Assessment will be conducted for the overhead powerline route alternatives as part of the separate Basic Assessment application process. - Who benefits in this area from this grid? Power generated by the proposed Juno We are led to believe it is for the main grid, but for example Tormin Mine is WEF will be fed into the national grid at applying to feed off the Sere Energy grid. the existing Eskom Juno substation. Refer to the entire Section 4 Need and Desirability of the Proposed Development and in particular Section 4.2 Wind Energy Facilities Contribution to Mitigating Climate Change in the FSR for further detail. Is this grid to support aquaculture? The grid will connect the power produced by the Juno WEF and feed into the National grid. It is estimated that from a 140 MW WEF, 150 000 customers (homes) can be electrified. - Will there be servitude roads on the boundary border that there remains Existing roads will be upgraded and access to the public and surrounding farms? existing access (including boundary roads) - 1 km from a residential area is not sufficient. will not be altered unless requested by the - Please could you create an artist impression of the turbines looking from the N, landowners. W and S in daylight and with the red lights at night. To get a true reflection of the footprint. The EAP has requested the Visual Specialist create a superimposed image of expected visual impact of wind turbines from the entrance to the town of Strandfontein (west of the proposed site). Additional visual impacts at night and from the north and south will be assessed during the EIA phase Visual Impact Assessment. - Has ARCUS Consultants requested the EIA from WWT and ESKOM for the The EAP has requested that all available SERE Wind Energy Project? knowledge and baseline data be
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received considered by the specialists during their EIA phase impact assessments. All renewable energy development within a 35 km radius of the site will be considered in the cumulative impact assessment of the Juno WEF. - Have ARCUS checked the Avi-fauna and Reports of killings to date recorded The EAP has requested the Avifaunal from Sere Wind Energy? Those statistics should be shared to grasp the impact Specialist to include available mortality in this area of 30 turbines only. Juno proposes 53 turbines. data from the existing Eskom Sere WEF as part of their EIA phase cumulative impact assessment, as the only operational WEF within a 35km radius of the proposed site. In November 2011 there was an application for Wind Turbines in this area by The EAP acknowledges that a previous SARGE WEF application to the north of the (South African Renewable Green Energy). Closer to Papendorp and Ebnehaezer. proposed Juno WEF was denied This was refused in August 2012 as the impacts far outweighed the project. authorisation due to significant negative impacts identified. In 2014 there was an application for a Powerline “ The Proposed AURORA – The Social Impact Assessment will JUNO & Aurora – Omega Powerlines , this was withdrawn due to the social consider this report in their assessment of economic impact along the coast. Attachment 2 Notification of withdrawal. the grid connection of the WEF. In Conclusion Representatives of the Ebenhaezer and - There was a lack of attendance from the Doringbaai, Papendorp and Doringbaai community are included in the Ebenhaezer community. Due to rural areas and communities it is imperative I&AP database and have been receiving their concerns are heard under NEMA REG 44 (2). communication regarding the project from the start of the process. The EAP will ensure that representative(s) of the Papendorp community are included in the PPP during the EIA phase. I believe there is a need for renewable energy systems and Wind Turbines at The EAP acknowledges support of the correct site play an important role. renewable energy development and WEFs, if the development site is appropriately located. There were no alternative sites identified by Arcus Consultants for this project. Pre-Feasibility assessment undertaken by The Matzikama Region North of the Olifants River where there is 120km of the developer is used to identify a suitable coastline that is identified in the spatial planning of Mining and Development WEF site. The proposed Juno WEF was zones would be far more lucrative and appropriate to seek an alternative site identified as a preferred site based on criteria that include environmental
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received where Powerlines are not crossing the Olifants River and closer to connecting constraints, land use and land availability, grids. grid connection availability, wind resource, site access and technical feasibility for construction. Section 6.2 of the FSR provides further detail on the site selection process. In light of the 20km of coastline that the Matzikama Municipality promotes The EAP has requested that the Social Tourism, Specialist assess the potential impact on I would sooner see a Tourism Development that creates constant employment tourism further during the EIA phase and grows the economy for a sustainable future of its residents. Social Impact Assessment and provide mitigation or enhancement measures. A literature review of the potential impact of wind farms on tourism will be undertaken as part of the EIA phase Social Impact Assessment. The Social Specialist will also interview representatives from the local tourism sector as part of the process. One of the highlights and beauty is our natural environment. Bird and Nature Further assessment of all applicable Lovers contribute a substantial portion towards our growing tourism economy. spatial planning documents and policies Birding, canoeing, surfing, hiking (full moon hiking) cycling; this is what draws will also be undertaken during the EIA people to come and enjoy our natural habitat in our area. phase Social Impact Assessment. The flora is unique and even though the Sandlaagte is a dry riverbed, its an extension finger of the Knersvlakte and is rich in conifortum uviforma and Crassula Barkelyi to name a few species. Phillip Desmet amongst other specialists have written documents of this area. Your IBA is comprehensive enough to highlight why this site is not conducive. Comment to maintain rows of turbines on Already the migration of birds is affected north, keep the erections of Turbines a similar track and minimise staggering on a similar track and not so staggered. The Olifants Estuary along with Bird Life will be taken into account during site has identified more than 200 coastal and Estuarine Bird Species of which 11 are layout updates in the EIA phase. red data species. The Estuary has been recorded to support more than 15000 individual Birds. Furthermore the EAP has requested that There are bat eared foxes too, bushbuck, Rock Kestrels, Egyptian geese, Sacred the Ecological Specialist, Avifaunal Ibis on that inland route. That it was tabled there are Rock Art Sites there is Specialist and Traffic Specialist take bound to be mounds of sites close by of bushman tools which we have found cognisance of and address comments along the coastal side of the Sandlaagte with Dr Antoinette Jeradino in 2010. herein pertaining to their respective fields Which again highlights tourism potential than Wind Turbines. of study in the EIA phase. The mode of transport and routes was barely touched and need investigation.
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received I fully support Mr Fouches comprehensive document that outlaid the objections. The EAP acknowledges support for the Strandfontein Ratepayers Association memorandum that is responded to in this table above. Adri La 9 July Email From: Adri La Meyer [mailto:[email protected]] From: Juno Meyer 2018 Sent: Monday, July 9, 2018 15:30 Sent: Monday, July 9, 2018 15:54 To: Juno
Kind regards, Dear Adri Adri Thank you very much for your valued comments on the proposed Juno WEF DSR.
We will address these comments within the Final Scoping Report and through further specialist study during the EIA phase, where required.
Thank you
Email attachment ENQUIRIES: The Environmental Assessment Mr Safwaan.Abrahams (Directorate: Development Management) Practitioner (EAP) acknowledges comment
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received on the Draft Scoping Report (DSR) DEPARTMENTAL REFERENCE: received from the Western Cape 16/3/3/6/4/2/1/F3/15/3168/18 (Development Management) Department of Environmental Affairs and Development Planning Directorate: DATE: 2018 -07- 03 Development Management.
The Board of Directors Arcus Consultancy Services South Africa (Pty) Ltd Office 220 Cube Workspace Icon Building Cnr Long Street and Hans Strijdom Road CAPETOWN 8001
For attention: Mr Ryan David-Andersen Tel: (021) 412 1529 E-mail: [email protected] BY E-MAIL
Dear Sir
COMMENT ON THE DRAFT SCOPING REPORT FOR THE PROPOSED DEVELOPMENT OF THE 140MW JUNO WIND ENERGY FACILITY ON THE REMAINING EXTENT OF THE FARM DE BOOM NO. 273, STRANDFONTEIN, MATZIKAMA MUNICIPALITY (DEA REF NO: 14/12/16/3/3/2/1074)
1. The Draft Scoping Report ("DSR") dated June 2018 as received by the Department on 8 June 2018 refers. Please find the Department's comments on the DSR. 2. Directorate: Development Management (Region 1) – Mr Safwaan Abrahams The EAP acknowledges the contact details ([email protected]: Tel: (021) 483 0780): provided for the commenter. 2.1 Strandfontein is a small seaside village situated south of the Olifants River The Environmental Assessment mouth. The town has evolved from a small rural beach resort to a bustling Practitioner (EAP) has requested the tourist destination with most of the locals being holidaymakers and retired Visual Specialist to assess potential visual people. Approximately 8km to the south of the site is Doring Bay, which is a impacts of the proposed Juno Wind small, isolated coastal town that can be access from Strandfontein via the Energy Facility (WEF) on the R 362,
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received main access road, the R362, which borders the seaside and West Coast Vredendal, Papendorp, Strandfontein and areas. The surrounding areas include Vredendal, Papendorp and Doring Bay Doring Bay during the Environmental which can be accessed by the R362 and will thus be visually exposed to the Impact Assessment (EIA) phase Visual proposed wind turbines. The Visual Impact Assessment ("VIA") must Impact Assessment (VIA). The VIA will therefore address the visibility of the proposed wind turbines from the include consideration of the potential towns, villages and the R362. The VIA must also address the potential of ‘flicker effect’, and assessment of the the flicker effect, which may cause a nuisance to motorists travelling on the potential visual impact on the scenic R362 and farmsteads near the proposed site. landscape of the West Coast. 2.2 Other criteria to consider when considering sites for wind energy facilities, is The social, visual and heritage assessment how vulnerable the landscape is to change. The West Coast is renowned for will assess the potential impact of the its scenic landscapes and the VIA must identify and report on the WEF on the scenic landscape. degree and significance of the potential impacts of the wind energy facility ("WEF") on the surrounding landscape and receiving environment. 2.3 Based on the information provided in the DSR and the Fauna and Flora The EAP has requested the Ecological Specialist Ecological Scoping Report dated April 2018, the far eastern Specialist provide clarity on the vegetation portion of the proposed site contains a Critical Biodiversity Area ("CBA"). types within the EIA phase Terrestrial The DSR and Ecological Scoping Report further refers to Sand Fynbos Ecology Impact Assessment. Nonetheless vegetation found on the site; however, it is unclear which type of Sand the area occupied by the Critical Fynbos (e.g. Leipoldtville Sand Fynbos) is referred to. The vegetation type Biodiversity Area (CBA) 1 and containing and ecosystem classification must be clarified in the Final Scoping Report the Sand Fynbos is considered a No-Go ("FSR"), Draft Environmental Impact Assessment ("EIA") Report and EIA Area for development. Ecological Report. Based on the Ecological Scoping Report dated April 2018, habitat loss in the CBA and Sand Fynbos section in the far east of the site is Methods to avoid this and other No-Go undesirable and not considered suitable for a WEF development. Although Areas will be provided in the no wind turbines are proposed in the identified sensitive area, associated Environmental Management Programme infrastructure is however proposed in this area as indicated in the (EMPr) to be produced in the EIA phase. environmental sensitivity map in the DSR. This Directorate does not support development in a CBA and advises that the highly sensitive area must be regarded as a "no-go" area for any development. The Draft EIA Report must indicate how this sensitive area will be avoided. 2.4 The acronym NPAES must be defined in the FSR. The Draft EIA Report must The EAP has requested the Ecological discuss how the most dated National Protected Areas Expansion Strategy is Specialist provide clarity on the relevant to the proposed development. conservation planning tools utilised for their impact assessment, including the National Protected Areas Expansion Strategy (NPAES).
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received 2.5 The DSR indicates that both Activity 14 of Listing Notice 1 and Activity 10 of The cumulative storage capacity of Listing Notice 3 of the EIA Regulations, 2014 (as amended) are applied for. dangerous goods expected during Please be advised that both listed activities will only be applicable if the construction may exceed 80m3. Therefore facility for the storage of the dangerous good(s) will be exactly 80m3. Activity 10 of Listing Notice 3 of the EIA Detailed information on the storage capacity of the dangerous goods facility Regulations 2014 (as amended) has been must be provided in the Draft EIA Report. removed and an Amended Application will be submitted to the Department of Environmental Affairs (DEA) alongside the Final Scoping Report (FSR). 2.6 Section 3.3.6 of the DSR states that the internal roads will have a width of Clarity on the internal road dimensions will between 6m - 12m. The specific dimensions (i.e. width and road reserve) of be provided as far as reasonably possible the internal roads must be indicated in the Draft EIA Report to confirm it in the Draft EIA Report. Activity 4 of Listing Notice 3 of the EIA Regulations, 2014 (as amended) is applicable to the proposed development. 2.7 The width and length of the existing farm access roads to be upgraded The width and length of existing farm must be be indicated in the Draft EIA Report to confirm if Activity 56 of roads that will be upgraded during the Listing Notice 1 of the EIA Regulations, 2014 (as amended) will be proposed development will be assessed triggered. further during EIA phase to confirm applicability of Listing Notice 1 Activity 56. 2.8 Clarity is sought to the applicability of Activity 6 of Listing Notice 2 of the Listing Notice 2 Activity 6 of the EIA EIA Regulations, 2014 (as amended) to the proposed development. Table Regulations 2014 (as amended) does not 5.1 of the DSR indicates that said listed activity is applicable as the apply to the proposed Juno WEF. An proposed development may require a water use licence ("WUL") in terms of Amended Application will be submitted to the National Water Act, 1998 (Act No. 36 of 1998) ("NWA"). Please note the DEA alongside the FSR. that a WUL application in terms of sections 21 (c) and (i) of the NWA, 1998 would not' necessarily trigger Activity 6 of Listing Notice 2 of the EIA Regulations, 2014 (as amended) if no emissions, pollution or effluent will be generated or released by the proposed development. 2.9 Please note that noise impacts must also be considered and assessed in The EAP has requested the Noise terms of the Western Cape Noise Control Regulations (Provincial Notice Specialist take cognisance of this 200/2013) of 20 June 2013. comment and assess potential noise impacts in terms of the Western Cape Noise Control Regulations (Provincial Notice 200/2013) of 20 June 2013 during the EIA phase Noise Impact Assessment. The co-ordinates of the boundaries of the subject farm, each location of the
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received 2.10 The co-ordinates of the boundaries of the subject farm must be provided in proposed wind turbines, the proposed the Draft EIA Report. In addition, the co-ordinates of the following substation, the construction yard, the components of the proposed WEF must also be provided: starting-, middle- and end- points of linear 2.10.1 Each location of the proposed 59 wind turbines; activities (i.e. proposed underground 2.10.2 The proposed substation; transmission cables and existing roads to 2.10.3 The construction yard; and be upgraded) will be provided in a Table 2.10.4 The starting-, middle- and end- points of linear activities (i.e. proposed within the Draft EIA Report. underground transmission cables and existing roads to be upgraded). 2.11 Please note that the FSR to be submitted to the competent authority must Public Participation Process (PPP) tasks include proof of notifying interested and affected parties of the background undertaken to date include inter alia information document and the DSR. The proof must include, inter alia, the Interested and Affected Party (I&AP) following: Initial Notification and I&AP Notification of Availability of Draft Scoping Report.
All PPP proof will be included in the Final Scoping Report (FSR) Appendix B. 2.11.1 If registered mail was sent, a list of the registered mail recipients, as To be provided in Appendix B of the FSR. obtained from the post office; 2.11.2 If regular mail was sent, a list of the mail recipients, as obtained from the No regular mail was sent during the PPP. post office; 2.11.3 If a facsimile was sent a copy of the facsimile report; No facsimile was sent during the PPP. 2.11.4 If an electronic mail was sent, a copy of the electronic mail and delivery Copies of all electronic mail reports; and correspondence relating to the proposed Juno WEF EIA PPP is included in the Comments and Responses Report.
No electronic mail delivery reports were activated. Two cases where I&AP Email Notifications were returned as ‘Undeliverable’ were followed up on to ensure that the I&AP received the applicable correspondence. 2.11.5 If a "mail drop" was done, a signed register of "mail drops". No mail drops were undertaken. 3. Please direct any enquiries to the official indicated in this correspondence The EAP acknowledges that contact should you require any clarity on any of the comments provided. details are provided for queries on the comments provided.
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received 4. The Department reserves the right to revise or withdraw comments and The EAP acknowledges the Department’s request further information based on any or new information received. right to withdraw comments and request further information.
Briaan Smit 9 July Email From: Briaan Smit [mailto:[email protected]] From: Juno 2018 Sent: Monday, July 9, 2018 20:40 Sent: Tuesday, July 10, 2018 9:22 Town To: Juno
Dear Briaan
Thank you very much for your comments on the proposed Juno WEF DSR.
We will address these comments within the Final Scoping Report and where further study is required during the EIA phase.
Thank you
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received The relevant farm is deemed to be zoned as Agricultural zone I. The Environmental Assessment Practitioner (EAP) acknowledges the current land use zoning of the proposed Juno WEF. The latest amendment to the Spatial Development Framework for the The EAP has requested the Social Municipality and the Integrated Development Framework were both Specialist assess planning fit with approved during May 2018 and is available on the Municipal website. The particular reference to the latest Spatial Development Framework for the Matzikama Municipality supports amendments of the Matzikama Local renewable energy structures and initiatives but subject to compliance to all Municipality Spatial Development relevant legislation. Framework and Integrated Development Framework during the EIA phase. The latest revision of the applicable zoning scheme regulations with regards The EAP has requested the Social to “Renewable Energy Structure” was published in Provincial Gazette 7061 Specialist take cognisance of Provincial dated 23 November 2012 and all applicable land use restrictions contain Gazette 7061 and applicable land use therein must be adhered to. restrictions therein as part of the EIA phase Social Impact Assessment. Specific comment with regards to the exact layout and location of each wind The Proposed Site Development Plan will turbine in relation to the above-mentioned land use restrictions can only be be updated based on Scoping phase provided when a detailed site development plan on an appropriate specialist input, and potentially further measurable scale is provided. updated based on specialist feedback during EIA phase. The updated Site Development Plan will be provided during EIA phase. The proposed wind energy facility needs to comply with “Development The EAP has requested the Social Principles” set out within Section 7 of the Spatial Planning and Land Use Specialist assess planning fit and Management Act, 2013 (No 16 of 2013) and Section 59 of the Western Cape compliance with the “Development Land Use Planning Act, 2014 (No 3 of 2014). Principles” set out within Section 7 of the Spatial Planning and Land Use Management Act, 2013 (No 16 of 2013) and Section 59 of the Western Cape Land Use Planning Act, 2014 (No 3 of 2014) within the EIA phase Social Impact Assessment. All structures (permanent or temporary) must comply with the provisions of Compliance with the National Building the National Building Regulations and Standards Act, 1977 (No 103 of 1977). Regulations and Standards Act, 1977 (No 103 of 1977) will be forthcoming from the proposed development.
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received Cognisance must be taken of the judgement handed down in the Cognisance of the Curiae Case nos.: CCT Constitutional Court of South Africa on 12 April 2012 on the issue of the 102/11 [2012] ZACC 8 & CCT 103/11 Minister of Mineral Resources vs. Swartland Municipality and Others and [2012] ZACC 7 and the judgement on Maccsand (Pty) Ltd vs. City of Cape Town (Chamber of Mines of South Africa these two cases will be maintained. and Agri South Africa as Amici Curiae Case nos.: CCT 102/11 [2012] ZACC 8 & CCT 103/11 [2012] ZACC 7) where relevant companies are restrained from conducting mining and / or prospecting activities until the properties are zoned correctly. Taking the above into account a land use application in terms of the Matzikama The EAP acknowledges that a land use Municipality: Land Use Planning By-Law, 2015 is also required. application in terms of the Matzikama Municipality: Land Use Planning By-Law, Also please note that this office reserves the right to provide contradictory 2015 is required. and/or amended comment and to request any additional or new information based on any additional or new information that is received.
Regards
Briaan Smit Pr. Pln A/1754/2013, MSAPI Stadsbeplanning / Town Planning MATZIKAMA MUNISIPALITEIT / MUNICIPALITY
027-201 3481 027-213 3238 98 Vredendal 8160 Kerkstraat / Church Steet 37 Vredendal 8160 EIA Admin 12 July Email From: EIAadmin [mailto:[email protected]] 2018 Sent: Thursday, 12 July 2018 15:23 Integrated To: Ashlin Bodasing
Coordination Good day. , Strategic Planning and Please find herein the attached letter for the above mentioned. Support
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received I hope you find all in order.
Thank you.
Kind Regards, EIA Admin Integrated Environmental Authorisations: Coordination, Strategic Planning and Support Tel: (012) 399 8630 / (012) 399 8529 Email: [email protected] Email Attachment Department: Comments from the Department of Environmental Affairs Environmental Affairs (DEA) Integrated REPUBLIC OF SOUTH AFRICA Environmental Authorisations: Coordination, Strategic Planning and Private Bag X 447·PRETORIA ·0001·Environment House·473 Steve Biko, Support Case Officer Mr Thando Booi Arcadia·PRETORIA Tel (+ 27 12) 399 9372 received and acknowledged.
DEA Reference:14/12/16/3/3/2/1074 Enquiries: Mr Thando Bool Telephone: (012) 399 9387 E-mail: [email protected]
Ashlin Bodasing Arcus Consultancy Services South Africa (Pty) Office 220 24 Hans Strijdom Avenue Icon Building 8001
Telephone Number: (021) 4121529 Email Address: [email protected]
PER E·MAIL / MAIL
Dear Madam
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received COMMENTS ON THE DRAFT SCOPING REPORT FOR PROPOSED 140 MW JUNO WIND ENERGY FACILITY,WESTERN CAPE PROVINCE
The application form and draft Scoping Report (SR) dated June 2018 as received by this Department on 11 June 2018 refers. This Department has the following comments on the abovementioned References to the 16km 132kV overhead application: powerline which is to be assessed in a separate application process will be Project Description: removed in the Environmental Impact The Department acknowledged that the information about the 16km 132kV Assessment (EIA) Report. Reference to power line which will be assessed in a separate application is provided in the the overhead powerline will remain within application, however, you are advised to not include the aforesaid activity as the Final Scoping Report (FSR). part of this project description as bullet point (accepted as information sharing). Reference to this evacuation route in the Application Form Project Description will be removed and an Amended Application will be submitted to the DEA alongside the Final Scoping Report. General Information [email protected] Please provide an email address of the contact person for the applicant. Environmental Assessment Practitioner Information: [email protected] Please provide a complete information of the EAP i.e. email address and a Arcus Consultancy Services South complete physical address. Africa (Pty) Ltd Office 220 Cube Workspace Cnr Long Street and Hans Strijdom Ave Cape Town 8001 Activities applied for: Activity 27 of GN R983, activity 6 of GN The Department has noted that both activity 27 of GN R983 and activity 15 of R984 and activity 10 of GN R985 have GN R984 have been applied for, both pertain to the clearance of indigenous been removed from the application. An vegetation. Please provide clarity on which one is triggered by this Amended Application will be submitted to development as both activities cannot be triggered by this development. the Department with the FSR. Please provide clarity on how this project will trigger activity 6 of GN R984, considering that the criteria for the requirement of a permit or a license i.e. if
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received the operation of a facility will result in generation or release of emissions, pollution or effluent. The Department has noted that you applied for both activity 14 of GN R 983 and activity 10 of GN R985, please ensure that you confirm the exact volume of dangerous goods to be stored in the facility as this will inform you of the applicable activity. Activity Coordinates 31°43'41.22''S 18°14'55.42''E Please provide four corner coordinates of the preferred site alternative in degrees, minutes and seconds. 31°41'41.37''S 18°18'39.55''E 31°43'48.19''S 18°21'24.81''E 31°45'44.72''S 18°15'33.32''E
Alternatives A Pre-Feasibility assessment undertaken Please provide a description of the identified alternatives for the proposed by the developer is used to identify a activity that are feasible and reasonable, including the advantages and suitable WEF site. The proposed Juno disadvantages that the proposed activity or alternatives will have on the WEF was identified as a preferred site environment and on the community that may be affected by the activity as per based on criteria that include Appendix 2, (2) (1) (h) (i-xi), of GN R.982 of 2014, as amended. environmental constraints, land use and land availability, grid connection availability, wind resource, site access and technical feasibility for construction. Section 6 of the FSR provides further detail on the site selection process (Section 6.2) as well as other alternatives considered. Alternatively, you should submit written proof of an investigation and Reasonable and feasible alternatives are motivation if no reasonable or feasible alternatives exist as per the provided under Section 6 of the FSR. No requirements of Appendix 2, (2) (1) (h) (x). alternative site for the proposed WEF was assessed during Scoping and EIA due to the site selection process detailed in Section 6.2 of the FSR. Impacts Assessment ‘Table E: Legislative Requirements for the This Department requests the EAP to familiarise themselves with the Content of this Final Scoping Report’ on requirements of Appendix 2 of GNR 982 of the EIA Regulations, 2014 (as Page viii of the FSR provides reference to amended) and ensure that the final SR submitted to this Department for Sections of the FSR where each aspect of consideration meets the requirements in terms of identifying, assessing and Appendix 2 of GNR 982 of the EIA Regulations 2014 (as amended) ‘Content
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received providing mitigation measures of the impacts on the alternatives and preferred of Scoping Reports’ is addressed within site. the FSR. Specialist Report A Traffic Impact Assessment will be Please ensure that the appropriate specialist input to address potential traffic conducted by the Traffic Specialist during impacts of this developments is used. EIA. Public Participation Process The EAP has addressed all I&AP Please ensure that all issues raised and comments received during the comments on the Draft Scoping Report circulation of the draft SR from the registered I&APs and organs of state which (DSR) received within the Comments and have jurisdiction (including this Department's Biodiversity Section) in respect Responses Trail (this table). of the proposed activity are adequately addressed in the final SR. Proof of correspondence with the various stakeholders must be included in the Proof of all I&AP correspondence is final SR, should you be unable to obtain comments, proof of the attempts that provided in Appendix B of the FSR. were made to obtain comments must be submitted to the Department. The Public Participation Process must be conducted in terms of Regulations 39, The Public Participation Process is being 40, 41, 42, 43 & 44 of the EIA Regulations 2014, as amended. conducted in terms of Regulations 39, 40, 41, 42, 43 & 44 of the EIA Regulations 2014 as amended. Cognisance is also taken of the DEA (2017) Public Participation guideline. General Comments ‘Table E: Legislative Requirements for the You are further reminded that the final SR to be submitted to this Department Content of this Final Scoping Report’ on must comply with all the requirements in terms of the scope of assessment and Page viii of the FSR provides reference to content of Scoping reports in accordance with Appendix 2 and Regulation 21(1) Sections of the FSR where each aspect of of the amended EIA Regulations, 2014. Appendix 2 of GNR 982 of the EIA Regulations 2014 (as amended) ‘Content of Scoping Reports’ is addressed within the FSR. Compliance with Regulation 21(1) of the EIA Regulations 2014 as amended is provided. Further note that in terms of Regulation 45 of the EIA Regulations 2014, this The EAP acknowledges the reference to application will lapse if the applicant fails to meet any of the timeframes Regulation 45 of the EIA Regulations 2014 prescribed in terms of the these Regulations, unless an extension has been as amended. granted in terms of Regulation 3(7). You are hereby reminded of Section 24F of the National Environmental The EAP and developer acknowledge the Management Act, Act No 107 of 1998, as amended, that no activity may reference to Section 24F of the National commence prior to an environmental authorisation being granted by the Environmental Management Act, Act No Department. 107 of 1998, as amended stating that no
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Comments and Responses on Draft Scoping Report Date Name Method Issue Response Received activity may commence prior to an environmental authorisation being granted by the Department. Yours faithfully Signature acknowledged by the EAP. Mr Sabelo Malaza Email address for the Applicant is provided Chief Director: Integrated Environmental Authorisations in this table above and in the Amended Department of Environmental Affairs Application to be submitted with the FSR. Signed by: Ma Olivia Letlalo Designation: Control Environmental Officer: Strategic Infrastructure Developments Date: 12/07/2018
Tel: AMDA Piero (021) Developments Email: none provided Granelli 461 Pty Ltd 3882 cc: Tel: Adri La Western Cape (021) Email: Meyer (DEA&DP) 483 [email protected] 2887 Tel: Matzikama Briaan (027) Local [email protected] Smit 483 Municipality 2481
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17 SUMMARY OF FINDINGS The FSR has provided a description of the proposed Juno WEF, and alternatives. It has also discussed the need and desirability of the proposed project. The FSR has documented the environmental and planning context for the proposed Juno WEF, the WEF site’s baseline environment and it has provided preliminary specialist assessments for the following areas of study: Geology, Soils and Agricultural Potential; Flora and Fauna (Terrestrial Ecology); Avifauna; Bats; Freshwater and Wetlands; Cultural Heritage, Archaeology and Palaeontology; Noise; Landscape and Visual; and Socio-economy. The specialist reports document the assessment of preliminary environmental impacts that may be experienced within the realms of both the biophysical and social environments. All specialist reports are included in Volume 2 of this report. This section summarises the Scoping Phase by providing an evaluation of the preliminary environmental impacts of this proposal. In doing so, it draws on the information gathered as part of the process, and the knowledge gained by the environmental assessment practitioners whilst undertaking the EIA.
17.1 Preliminary Significance Assessment Table 17.1 summarises the social and biophysical impacts identified in terms of their degrees of significance, both before and after mitigation. Note that the assessed significance of these impacts may change during the Environmental Impact Assessment Phase, as more detail regarding the proposed WEF design and layout becomes available.
Table 17.1: Summary of Scoping Phase Preliminary Impact
Construction Phase Impacts
Constructio Intensit Significanc Confidenc Extent Duration Status Probability n Phase y e e
Geology, Soils and Agricultural Potential Impact
Loss of Agricultural L L L Negative L L L land With L L L Negative L L H Mitigation Increased soil erosion L M M Negative M M M hazard With L L L Negative L L H Mitigation Terrestrial Ecological Impacts
Impacts on vegetation and plant L H M Negative M H H species of conservation concern (scc)
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Constructio Intensit Significanc Confidenc Extent Duration Status Probability n Phase y e e
With L H M Negative M M H Mitigation Direct and indirect faunal L L M Negative M H H impacts With L L M Negative M M H Mitigation Avifauna Disturbance through construction of a building works depot, turbines themselves, M M M Negative H M M roads, and associated human activity, noise of construction. With M L M Negative M M-L M Mitigation Bats Destruction of natural L H M Negative M M M vegetated areas With L H L Negative M M M Mitigation Wetlands and freshwater Increase in sedimentation and erosion L M L Negative M H H within the development footprint With L L L Negative L L H Mitigation Impact on localized L M L Negative M H H surface water quality With L L L Negative L L H Mitigation Noise Construction L L L Neutral L L H Noise With L L L Neutral L L H Mitigation
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Constructio Intensit Significanc Confidenc Extent Duration Status Probability n Phase y e e
Visual Impact on the landscape H H M Negative H M M character With H H L Negative M M M Mitigation Impact on sensitive M H M Negative M L M receptors in the area With H H L Negative L L M Mitigation Impact of artificial lighting of the M H M Negative M L M proposed activity With L H L Neutral L L H Mitigation Impact of reflectivity M H M Negative M L H and glare of the structures With L H L Neutral L L H Mitigation Impact of desertification L H L Negative H M H of the landscape. With L H L Neutral L L H Mitigation Heritage Impacts to archaeological L H L Negative L L L resources With L H L Negative L L H Mitigation Impacts to palaeontogical L H L Negative L L H resources With L H L Negative L L H Mitigation Impacts to L H H Negative L L H graves With L H H Negative L L H Mitigation Impacts to cultural M L H Negative M H H landscapes
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Constructio Intensit Significanc Confidenc Extent Duration Status Probability n Phase y e e
With L L M Negative M H H Mitigation Social Impact of employment and business M L M Positive M M H creation opportunities With H L H Positive M H H Mitigation Impact of the presence of construction M L M Negative M M H workers in the area on local communities With M L L Negative L L H Mitigation Impact of job seekers on M L L Negative L L M local communities With M L L Negative L L M Mitigation Risk to safety, livestock, farm M L M Negative M M H infrastructure and farming operations With M L L Negative L L H Mitigation Impact of increased risk M L M Negative M M H of fires With M L L Negative L L H Mitigation Impacts associated with M L M Negative M M H construction vehicles With M L L Negative L L H Mitigation Impact on farmland due to M L M Negative M M H construction related activities
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Constructio Intensit Significanc Confidenc Extent Duration Status Probability n Phase y e e
With M L L Negative L L H Mitigation
Operational Phase Impacts
Operational Duratio Significanc Extent Intensity Status Probability Confidence Phase n e Geology, Soils and Agricultural Potential Impact Loss of Agricultural L L L Negative L L L land With L L L Negative L L H Mitigation Increased soil L M M Negative M M M erosion hazard With L L L Negative L L H Mitigation Terrestrial Ecological Impacts Increased soil L H M Negative M H H erosion With L L L Negative L L H Mitigation Increased alien plant L H M Negative M H H invasion With L L L Negative L L H Mitigation Faunal L H M Negative M H H Impacts With L H L Negative L M H Mitigation Impacts on Critical Biodiversity L H M Negative M H H Areas and NPAES Focus Areas With L H L Negative L M H Mitigation Avifauna Displacement of priority L M L Negative M M M species With L M L Negative M M M Mitigation
Direct impact L M M Negative H H M and death of
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Operational Duratio Significanc Extent Intensity Status Probability Confidence Phase n e priority species With L M M Negative M M M Mitigation Bats Fatality of L M M Negative M H M individuals With L M L Negative M M M Mitigation Disturbance of bat L M M Negative M M M community With L M L Negative M M M Mitigation Wetlands and freshwater Increase in sedimentation and erosion within the development footprint during the L M L Negative M H H construction phase and to a lesser degree the operational phase With L L L Negative L L H Mitigation Noise Operational L H L Neutral L L H Noise (Day) With L H L Neutral L L H Mitigation Operational L H M Negative M M H Noise (Night) With L H L Neutral L L H Mitigation Visual Impact on the landscape H H M Negative H M M character With H H L Negative M M M Mitigation Impact on sensitive M H M Negative M L M receptors in the area
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Operational Duratio Significanc Extent Intensity Status Probability Confidence Phase n e With H H L Negative L L M Mitigation Impact of artificial lighting of the M H M Negative M L M proposed activity With L H L Neutral L L H Mitigation Impact of reflectivity and M H M Negative M L H glare of the structures With L H L Neutral L L H Mitigation Impact of desertification L H L Negative H M H of the landscape. With L H L Neutral L L H Mitigation Heritage Impacts to cultural M M M Negative M H H landscapes With M M M Negative M H H Mitigation Social Implementati on of clean, renewable M M M Positive M M H energy infrastructure With M M M Positive H H H Mitigation Impact of employment and business M M L Positive M M H creation opportunities With M M M Positive M H H Mitigation Assessment of benefits associated with income M M L Positive L L H generated for affected farmer(s) With M M M Positive M H H Mitigation
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Operational Duratio Significanc Extent Intensity Status Probability Confidence Phase n e Assessment of benefits associated with M H M Positive M L H establishmen t of community trust With M H H Positive H H H Mitigation Impact on sense of place and rural M M M Negative M M M character of the landscape With M M M-L Negative M M M Mitigation Impact of potential impact on M M M Negative L L M property values With M M L Negative L L M Mitigation Impacts on tourism in the M M L Negative L L H region With M M L Negative L L H Mitigation
Decommissioning Phase Impacts
Decommissi Exten Intensit Significanc Duration Status Probability Confidence oning Phase t y e Bats Disturbance of bat L L M Negative M M M community With L L L Negative L L M Mitigation Noise Decommission L L L Neutral L L H ing Noise With L L L Neutral L L H Mitigation Visual Impact on the landscape H H M Negative H M M character
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Decommissi Exten Intensit Significanc Duration Status Probability Confidence oning Phase t y e With H H L Negative M M M Mitigation Impact on sensitive M H M Negative M L M receptors in the area With H H L Negative L L M Mitigation Impact of artificial lighting of the M H M Negative M L M proposed activity With L H L Neutral L L H Mitigation Impact of reflectivity M H M Negative M L H and glare of the structures With L H L Neutral L L H Mitigation Impact of desertification L H L Negative H M H of the landscape. With L H L Neutral L L H Mitigation Heritage Impacts to cultural M L M Negative M H H landscapes With L L L Negative M H H Mitigation Social Impacts associated with decommissio M M M Negative M M H ning – loss of jobs and associated income With M L L Negative L L H Mitigation
Cumulative Phase Impacts
Cumulative Exten Intensit Significanc Confidenc Duration Status Probability Phase t y e e Geology, Soils and Agricultural Potential Impact
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Cumulative Exten Intensit Significanc Confidenc Duration Status Probability Phase t y e e Increased soil erosion if two or more L M M Negative M M H facilities utilize the same terrain With L L L Negative L L H Mitigation Terrestrial Ecological Impacts Cumulative habitat loss and impact on M H M Negative M H H broad-scale ecological processes With L H L Negative L M H Mitigation: Avifauna Displacement and direct mortality of H M M Negative H H M priority species With M M M Negative M M M Mitigation Bats Accumulate of disturbance of M M M Negative M M M bat community With M M L Negative M M M Mitigation Accumulate of M M M Negative M M M Fatality With M M L Negative M M M Mitigation Wetlands and freshwater Impact during the construction L M L Negative M H H and operational phases With L L L Negative L L H Mitigation Visual Impact of increased H L M Negative M M H traffic during the
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Cumulative Exten Intensit Significanc Confidenc Duration Status Probability Phase t y e e construction phase.
With H L M Negative M M M Mitigation Impact of construction L L M Negative M M H activities With L L M Negative L M H Mitigation Impact of renewable energy H H M Negative H M M projects in the region. With H H L Negative M M M Mitigation Heritage Impacts to archaeological M H M Negative M H H resources and graves With L H L Negative L H H Mitigation Impacts to palaeontologic L H M Negative M L H al resources With L H L Positive L L H Mitigation Impacts to L H H Negative H L H graves With L H L Negative L L H Mitigation Impacts to cultural M M M Negative M H H landscapes With M M M Negative M H H Mitigation Social Impacts on sense of place and M M M Negative M M H the landscape With M M M Negative M M H Mitigation Impacts on M L L Negative L L H local services
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Cumulative Exten Intensit Significanc Confidenc Duration Status Probability Phase t y e e With M L L Negative L L H Mitigation Impacts on local M H M Positive M L H economy With M H M Positive H M H Mitigation
17.2 Preliminary Environmental Sensitivity Map A combined preliminary environmental constraints map was created using the specialists scoping phase findings (Figure 17.1). This map includes the initial proposed layout. Using this map, and taking all specialist recommendation into consideration, a revised alternative layout is being created, taking all specialists recommendations into consideration. This revised layout will be assessed as the preferred layout in the EIA phase.
17.3 Conclusion Based on the preliminary assessment of impacts for the proposed development it can be concluded that at this stage of the process the project can proceed into the EIA phase. The specialist’s assessments have identified areas of further investigation and these will be assessed in further detail during the EIA Phase, together with any additional impacts or concerns raised during the public participation process. A preliminary layout was produced and provided to specialists for consideration during the scoping phase. This layout will be revised during the EIA phase of the process to be informed by buffers and constraints provided by specialists (Figure 17.1). Any additional constraints and buffers recommended by the specialists during the EIA phase, will be taken into consideration and a final layout will be produced and submitted as part of the Final EIA Report. Comments received from I&APs during the public participation comment period has been taken into consideration to inform the final scoping report and plan of study for EIA.
18 PLAN OF STUDY FOR EIA PHASE Tasks for the EIA Phase will be undertaken in accordance the 2014 EIA Regulations as amended by GN R326 of 2017. In particular, Appendices 3 and 4 of R326 Environmental Impact Assessment Regulations, which lists the Contents of EIA Reports and EMPrs. The environmental impact assessment process will need to be undertaken in line with an approved plan of study for EIA Phase. The EIA Phase will: Provide an overall assessment of the social and biophysical environments affected by the proposed development; Confirm the need and desirability of the proposed development within the proposed location; Assess potentially significant impacts (direct, indirect and cumulative) associated with the proposed WEF and its grid connection; Identify and recommend appropriate mitigation measures for potentially significant environmental impacts; and Undertake an inclusive PPP to ensure that I&APs are afforded the opportunity to participate, and that their issues and/or concerns are recorded. The findings from the PPP and the specialists’ investigations shall be documented in the Environmental Impact Assessment Report and Environmental Management Programme (EMPr), the objectives of which will be to: determine the policy and legislative context within which the activity is located and document how the proposed activity complies with and responds to the policy and legislative context; describe the need and desirability of the proposed activity, including the need and desirability of the activity in the context of the preferred location; identify the location of the development footprint within the preferred site based on an impact and risk assessment process inclusive of cumulative impacts and a ranking process of all the identified
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development footprint alternatives focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects of the environment; determine the: nature, significance, consequence, extent, duration and probability of the impacts occurring to inform identified preferred alternatives; and degree to which these impacts- can be reversed; may cause irreplaceable loss of resources, and can be avoided, managed or mitigated; identify the most ideal location for the activity within the preferred site based on the lowest level of environmental sensitivity identified during the assessment (best practicable environmental option); identify, assess, and rank the impacts that the activity will impose on the preferred location through the life of the activity; identify suitable measures to avoid, manage or mitigate identified impacts; and identify residual risks that need to be managed and monitored. The EIA Phase will address potential environmental impacts and benefits associated with all phases of the project including construction, operation and decommissioning. The EIA Report will aim to provide the DEA with sufficient information to make an informed decision regarding the proposed WEF. All feasible alternatives (including the ‘do nothing’ alternative) will be assessed. The EIA phase will in particular address the public comments, concerns and issues identified during the Scoping phase. All specialists have been provided Scoping phase public comments applicable to their fields of study for further assessment during EIA. Details on comments received and the specialist study required to address these comments during the EIA phase is provided in Section 16.3 Synopsis of Key Issues.
18.1 Plan of Study Requirements As per Appendix 2 of the Environmental Impact Assessment Regulations 2014 amended by GN R326 of 2017, promulgated in terms of the NEMA, a Plan of Study for EIA Phase must be included within the Scoping Report and it is to include the following: “(i) a description of the alternatives to be considered and assessed within the preferred site, including the option of not proceeding with the activity; (ii) a description of the aspects to be assessed as part of the environmental impact assessment process; (iii) aspects to be assessed by specialists; (iv) a description of the proposed method of assessing the environmental aspects, including aspects to be assessed by specialists; (v) a description of the proposed method of assessing duration and significance; (vi) an indication of the stages at which the competent authority will be consulted; (vii) particulars of the public participation process that will be conducted during the environmental impact assessment process; and (viii) a description of the tasks that will be undertaken as part of the environmental impact assessment process; (ix) identify suitable measures to avoid, reverse, mitigate or manage identified impacts and to determine the extent of the residual risks that need to be managed and monitored.”
18.2 Alternatives Alternatives considered within this report include alternative site locations, renewable energy/energy technologies and the “no-go option”. The findings of the specialists’ studies and the public participation process will continue to be used to inform the detailed layout design of the WEF. A preferred alternative turbine layout is being produced with the findings of the Scoping phase specialist studies. The approach is an iterative design process which will take cognisance of any potential significant impacts through avoidance through design, where possible. This will be referred to within the EIA Phase as mitigation to be embedded in the layout, or simply ‘embedded mitigation’.
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The significance of the impacts associated with the preferred alternative for the Juno WEF will be assessed in the specialist studies, as part of the EIA. The ‘no development’ alternative, or ‘no-go option’ will also be further assessed during the EIA Phase.
18.3 Aspects to be assessed by Specialists and Methodologies Employed The following specialist investigations and assessments shall be undertaken by the project team for the EIA Phase: Flora and Fauna (Terrestrial Ecology); Avifauna; Bats; Freshwater and Wetlands; Noise; Landscape and Visual; Cultural Heritage, Archaeology and Palaeontology; Socio-economics; and Access, Traffic and Transportation.
The methodologies for each investigation are outlined below.
Geology, Soils and Agricultural Potential No further Soil Specialist Study will be undertaken in EIA phase due to the low agricultural potential of the soils of the proposed Juno WEF site. The Soil Scoping Report provides sufficient detail for the EIA phase, including recommendations for mitigation of negative impacts, i.e. erosion and loss of potentially arable agricultural land.
18.3.1 Fauna and Flora (Terrestrial Ecology) The Terrestrial Ecology Scoping Report is based on two seasons of assessment at the site and includes detailed fauna and flora surveys of the site. As such, the field-assessment component of the study is considered complete and the results obtained are considered thorough and reliable. As such, the major tasks remaining going into the EIA phase are around assessing the final layout, assessing the cumulative impacts associated with the development in more detail and making the appropriate recommendations with regards to the most appropriate mitigation and avoidance measures to be included in the EMPr for the development. Based on the results of the current study and the features of the site, the following activities and outputs are planned to inform the EIA phase of the development: Characterise the faunal communities at the site in greater detail. Camera traps have been deployed at the site and the information on faunal distribution and abundance at the site will be included in the EIA. This will be complemented with the information from the small mammal trapping and reptile surveys conducted, which have not been fully detailed here. Provide a more detailed assessment of cumulative impact associated with the development of the site. Including an assessment of the extent of habitat lost to wind energy development in the area to date and the likely future potential loss from the current as well as other proposed developments in the area. Evaluate, based on the site attributes and final layout of the development, what the most applicable mitigation measures to reduce the impact of the development on the site would be and if there are any areas where specific precautions or mitigation measures should be implemented. Assess the impacts identified above in light of the site-specific findings and the final layout for assessment in the EIA Phase to be provided by the developer.
18.3.2 Avifauna The Avifauna Scoping Report identified the following species that require further assessment of the local population: 16 collision-prone species including six red data species (Ludwig’s Bustard, White Pelican, Black Harrier, Verreaux’s Eagle, Martial Eagle and Secretarybird) that will occur or pass through the site. Other species that feature prominently in fatality records from South African wind farms (e.g. Jackal
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Buzzards) are also likely to be impacted and all may require mitigation depending on their frequency of occurrence and spatial use of the proposed site. Pans in the north-east of the site will also require close study as they are likely to attract wetland species at times of flooding and should be avoided for development. All collision-prone species require further study over a 12-month period of pre-construction monitoring covering all seasons to record their occurrence and use of the proposed wind energy facility. This is essential in reducing the possible threats to them. Issues related to the collision and electrocution of birds should be investigated in more detail during the full EIA phase. In particular, the significance of bird collisions with the turbines will be assessed to determine whether the risk warrants mitigation such as no- go areas for turbine placement. This will be assessed mainly in terms of (i) the actual abundance of priority bird species in the area, and (ii) the distribution of relevant microhabitats and food resources. Thus, the EIA pre-construction phase that will follow the BARESG guidelines (Jenkins et al. 2015) will include: (i) sample surveys of large terrestrial species, raptors and endemic passerines within the study area to determine the relative importance of local populations of these key taxa; (ii) estimates of the extent and direction of possible movements of these species within/through the anticipated impact zone of the wind energy facility, in relation to the distribution of available resources – e.g. nesting or roosting sites (especially existing power lines) and foraging areas; (iii) estimates of the heights at which each collision-prone species fly through the area to determine the risk of collision; (iv) identification of the least sensitive/lowest risk areas to locate wind turbines within the broader study area, in terms of (i) and (ii) above; (v) four field site visits (one remaining in EIA phase), covering all seasons, incorporating at least 12 hours per vantage point for each area, covering a maximum of 2km view sheds per VP; and (vi) a quantified assessment of the Significance (S) of the impacts to the birds in relation to the Magnitude (M), Extent (E), Duration (D) and Probability of Occurrence (P), where S = (M + E + D)P
The results will include a more detailed assessment of all impacts, recommended mitigation measures where necessary (particularly regarding the siting of turbines) and, perhaps most importantly, a comprehensive, long-term programme for monitoring actual impacts from pre- to post-construction phases of the development. This will improve our understanding of the long-term effects of wind energy developments on South African avifauna.
The final season of bird monitoring will be conducted during the EIA phase allowing a detailed bird sensitivity map to be produced.
18.3.3 Bats The bat impact assessment will be conducted as per the following methodology: Describing the baseline environment for bats through survey and desk top data; Determining the sensitivity of the bats utilising published data sources; Identifying and characterising potential impacts of developing the proposed Juno WEF and its grid connection, considering the intensity, extent, duration and reversibility of the impact; Feeding into the design of the proposed WEF and its grid connection; Determining the significance of impacts in line with the resultant design; Considering cumulative impacts in terms of other developments in the area, primarily WEF developments; Developing strategies where possible for mitigation of negative impacts, enhancement of positive impacts and recording monitoring measures. The latter will include management practices, which shall inform the EMPr; and Describing the residual effects, i.e., those remaining after mitigation, management and implementation of the EMPr. In line with best practise guidelines for environmental assessments at proposed WEFs, 12 months of bat monitoring were undertaken for the project. Using this data the revised layout will be assessed in an impact assessment report. The outcome of the EIA study will thus be a description of bat activity at the project, a more detailed evaluation of potential risks/impacts to bats (including cumulative impacts), and recommendations for the proposed Juno WEF to reduce negative impacts and enhance positive impacts.
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18.3.4 Freshwater and Wetlands The following aquatic aspects will be finalised in the EIA phase: • Further assessment of the study area, which will cover a 500 m development buffer in relation to available information on the aquatic systems within the study area. This includes the Juno WEF site boundary and the associated transmission line; • Mapping data, demarcating the relevant local drainage areas and catchments of the respective streams and wetlands and other wetland areas within a 500 m radius of the study area. This will demonstrate, from a holistic point of view the connectivity between the site and the surrounding regions, i.e. the zone of influence; • Mapping data that demarcates aquatic and wetland vegetation units delineated to a scale of 1:10 000, following the methodology described by the DWS, together with a classification of delineated wetland areas, according to the methods contained in the Level 1 WET-Health methodology and the latest Wetland Classification System (Ollis et al., 2013) after a site visit has been conducted; • The final site visit will also include the determination of the Present Ecological State (PES) and Ecological Importance and Sensitivity (EIS) of any waterbodies, estimating their biodiversity, conservation and ecosystem function importance with regard to ecosystem services; • Verify recommend buffer zones and No-go areas around any delineated aquatic vegetation areas based on the relevant legislation (e.g. Biodiversity Conservation Plan guidelines) or best practice; • Provide a detailed impact assessment based on the methodology provided by the EAP; • Provide mitigations regarding project related impacts, including engineering services that could negatively affect demarcated aquatic vegetation units; • Recommend specific actions that could enhance the aquatic functioning in the areas, allowing the potential for a positive contribution by the project; and • Supply the client with geo-referenced GIS shape files of the waterbodies as per the required specifications supplied. The above detail can also be used for inclusion in the respective water use license application / GA documents submitted to DWS, noting they will require the completion of the Risk Assessment Matrix (DWS Notice 509 of 2016). This will determine the WUL/GA process, which must be completed in their format and signed by a registered Professional. The Risk Matrix will only be finalised once the roads and infrastructure layouts, together with preliminary designs can be provided by the proponent.
18.3.5 Noise The Environmental Noise Impact Report will include: the purpose of the investigation; a brief description of the planned development or the changes that are being considered; a brief description of the existing environment including, where relevant, the topography, surface conditions and meteorological conditions during measurements; the identified noise sources together with their respective sound pressure levels or sound power levels (or both) and, where applicable, the operating cycles, the nature of sound emission, the spectral composition and the directional characteristics; the identified noise sources that were not taken into account and the reasons as to why they were not investigated; the identified Potentially Sensitive Receptors and the noise impact on them; where applicable, any assumptions, with references, made with regard to any calculations or determination of source and propagation characteristics; an explanation, either by a brief description or by reference, of all measuring and calculation procedures that were followed, as well as any possible adjustments to existing measuring methods that had to be made, together with the results of calculations; an explanation, either by description or by reference, of all measuring or calculation methods (or both) that were used to determine existing and predicted rating levels, as well as other relevant information, including a statement of how the data were obtained and applied to determine the rating level for the area in question; the location of measuring or calculating points on a map; quantification of the noise impact with, where relevant, reference to the literature consulted and the assumptions made; alternatives that were considered and the results of those that were investigated;
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a list of all the interested or affected parties that offered any comments with respect to the environmental noise impact investigation (if comments are received); a detailed summary of all the comments received from interested or affected parties as well as the procedures and discussions followed to deal with them (if comments are received); conclusions that were reached; proposed recommendations including potential mitigation measures; any follow-up investigation which should be conducted at completion of the project as well as at regular intervals should the projects be commissioned so as to ensure that the recommendations of this report will be maintained in the future.
18.3.6 Landscape and Visual The construction of the proposed Juno Wind Energy Facility will have a defined visual impact on its surroundings. In order to successfully determine the exact extent of this impact, the anticipated impact will be assessed during the EIA phase. In this regard, the proposed Plan of Study for EIA is as follows: Determine the distance/proximity of the respective observers from the proposed facility The distance between the observer and the observed activity is an important determinant of the magnitude of the visual impact. This is due to the visual impact of an activity diminishing as the distance between the viewer and the activity increases. Viewsheds are categorised into three broad categories of significance, namely: Foreground: The foreground is defined as the area within 1km from the observer within which details such as colour, texture, styles, forms and structure can be recognised. Objects in this zone are highly visible unless obscured by other landscape features, existing structures or vegetation. Middle ground: The middle ground is the area between 1km and 3km from the observer where the type of detail which is clearly visible in the foreground becomes indistinguishable. Objects in the middle ground can be classified as visible to moderately visible, unless obscured by other elements within the landscape. Background: the background stretches from approximately 3km onwards. Background views are only distinguishable by colour and lines, while structures, textures, styles and forms are often not visible (SRK Consulting, 2007). Determine the nature of the respective observation points Each observation point will be categorised according to its location and significance. Differentiation is made between tourist-related corridors, including linear geographical areas visible to users of a route or vantage points and residential areas (including farmsteads and townscapes). The visual impact considered acceptable is dependent on the type of receptors. Visual rating between high (e.g. residential areas, nature reserves and scenic routes or trails), moderate (e.g. sporting or recreational areas, or places of work), or low sensitivity (e.g. industrial, mining or degraded areas) will be allocated to each observation point. Determine the visual absorption capacity of the environment Visual absorption capacity (VAC) refers to the capacity of the receiving environment to absorb or screen the potential visual impact of the proposed activity. The VAC is primarily a function of the vegetation and will vary depending on the nature/density of the vegetation growth. The VAC would also be high where the environment can readily absorb the structure in terms of texture, colour, form and light / shade characteristics of the structure. The VAC also generally increases with distance, where discernible detail in visual characteristics of both environment and structure decreases. The potential of the landscape to conceal the proposed activity will therefore be assessed in the EIA phase. A rating of high (effective screening by topography and vegetation), moderate (partial screening) and low (little screening) will be allocated to each observation point. Determine the visual exposure Visual exposure is defined as the relative visibility of a project or feature in the landscape. This is often also referred to as the zone of visual influence which is an area subject to the direct visual influence of a particular project. Exposure or visual impact tends to diminish exponentially with distance. A high (dominant or clearly visible), moderate (recognisable to the viewer) or low exposure
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(not particularly visible to the viewer) rating will be allocated to each observation point during the EIA phase. Determine the visual intrusion of the proposed activity in the landscape The potential of the activity to fit into the surrounding environment is a very important determinant. The visual intrusion relates to the context of the proposed activity while maintaining the integrity of the landscape. A rating of high (noticeable change), moderate (partially fits into the surroundings) or low (blends in well with the surroundings) will be allocated to each observation point during the EIA phase. In addition to the above, the cumulative visual impact of the proposed activity in the landscape should also be determined during the EIA phase. This phase should also be supplemented by appropriate mitigation measures to be employed to lessen the potential visual impact of the proposed activity on the respective observers.
18.3.7 Cultural Heritage, Archaeology and Palaeontology The following key issues will be investigated during the EIA Phase: Archaeology: The physical remnants of human activity need to be identified and assessed through physical site inspection, mapped and assigned field grades. This is a field intensive process, as there are no databases in existence that have enough detailed information that will allow the assessment to take place at desktop level. Palaeontology: The area is of low palaeontological sensitivity. However HWC have requested a specialist assessment of potential palaeontological impacts. This will be conducted during the EIA process. Landscape and setting: The assessment of the landscape as a heritage resource will require the integration of findings of the visual impact assessment as well as consideration of the methods of landscape characterisation and grading to produce an integrated statement of impact for purposes of the EIA.
18.3.8 Socio-Economics The identification and assessment of social impacts will be informed by the Guidelines for specialist SIA input into EIA Processes (adopted by DEA&DP in the Western Cape in 2007). The Guidelines are based on accepted international best practice guidelines. The approach will include: Review of existing project information, including the Planning and Scoping Documents; Collection and review of reports and baseline socio-economic data on the area (IDPs, Spatial Development Frameworks etc.); Site visit and interviews with key stakeholders in the area including local land owners and authorities, local community leaders and councillors, local resident associations and residents, local businesses, community workers etc.; Identification and assessment of the key social issues and opportunities; Preparation of a Social Impact Assessment (SIA) Report, including identification of mitigation/optimisation and management measures to be implemented; and Finalisation of the SIA Report. The methodology for assigning significance ratings is to be supplied by the EAP. In addition to the baseline socio-economic data for the area, the following project related information will be sourced and used to inform the SIA: Construction Phase This phase includes construction of the WEF and all related infrastructure, such as transmission lines, access roads etc. Comments received from I&APs during the PPP; A draft illustration (plan) of the proposed lay-out(s) of the turbines (including an indication of the phasing sequence on the site), supporting structures and infrastructure; Duration of the construction phase (months); Number of people employed during the construction phase; Breakdown of number of people employed in terms or low skilled, semi-skilled and skilled; Estimate of the total wage bill for the construction phase and breakdown in % as per skills categories; Estimate of total capital expenditure for construction phase; Indication of where construction workers will be housed;
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Opportunities for on-site skills development and training; Description of the typical activities associated with the construction phase, specifically on-site construction activities. This includes a description of how the large components associated with the WEF and grid connection will be transported to the site and assembled; The size of the vehicles needed to transport the components and the routes that will be used to transport the large components to the site, and an estimate of the number of vehicle trips required and duration of each trip; and Information on the nature of the agreements with the affected landowners, specifically with regard to compensation for damage to land, infrastructure etc. Operational Phase Operating budget per annum; Total number of people employed; Breakdown in terms of skills levels; Annual wage bill; Typical activities associated with the operational phase; Information on opportunities for skills development and training; Typical lifespan of proposed WEF plant; Information on the lease / rental agreements with local landowners and or communities, specifically with regard to issues relating to compensation for damage to infrastructure and loss of livestock etc. This information is required so as to indicate how local landowners and communities stand to benefit from the project; and Information of Community Trusts to be established as part of the project. The identification and assessment of social impacts will be informed by the Guidelines for specialist SIA input into EIA Processes (adopted by DEA&DP in the Western Cape in 2007). The Guidelines are based on accepted international best practice guidelines. The approach will include: Review of existing project information, including the Planning and Scoping Documents; Collection and review of reports and baseline socio-economic data on the area (IDPs, Spatial Development Frameworks etc.); Site visit and interviews with key stakeholders in the area including local land owners and authorities, local community leaders and councillors, local resident associations and residents, local businesses, community workers etc.; Identification and assessment of the key social issues and opportunities; Preparation of a Social Impact Assessment (SIA) Report, including identification of mitigation/optimisation and management measures to be implemented; and Finalisation of the SIA Report.
18.3.9 Traffic Management Plan As part of the EIA phase a Traffic Management Plan will be produced. Traffic Impact Statement will detail the following: Potential transport impacts of the proposed WEF on the surrounding and existing road network; Status quo of existing site conditions; Specific traffic needs during each phase of the project; Transport plan for the transportation of equipment to site; Site access locations suitable for the WEF; Non-Motorised Transport (NMT) and Public Transport (PT) requirements statement; Infrastructure upgrades, in order to mitigate negative transport impacts of development Infrastructure where applicable; and Reporting. Submit a Traffic Statement addressing: The proposed transmission power line’s impact, or lack thereof, on traffic. Methodology It is standard industry practice that the Traffic Impact Statement (TIS) should consider a worst-case scenario. The TIS will focus on the potential transport impacts of the new development on the surrounding road network and propose mitigation measures of negative transport impacts. The TIS will be conducted in accordance with the Committee of Transport Officials (COTO) TMH 16 Manual for Traffic Impact Assessment and Site Traffic Assessment, August 2012. A site visit during EIA phase to project site which will assess the following: Project site location;
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Establish the existing traffic conditions and traffic, NMT and PT infrastructure in the immediate vicinity of project site; Explore site access options; Access main route alternatives for transportation of equipment; and Evaluate road conditions and any initial site distance issues at alternatives and intersection.
Collating Existing Information Gather existing data on the surrounding road network and traffic characteristic within the surrounding area. Contact the local authority and SANRAL to collect all reference materials required, including: Schedule of planned road improvements; Any existing cadastral information available from the client / municipality; and Satellite imagery and/or aerial photography for mapping purposes.
Site Access In order to make provision for vehicles which are expected to travel to and from the development, an analysis will be done and suggestions/recommendations will be made on suitable site access locations and road alternatives.
Transportation Plan A high level transportation plan will be produced which will evaluate: Origins and destinations of equipment; The best possible haulage route which will meet freight and transport requirements during the transportation of equipment to site; and Confirm the associated clearances required for the necessary equipment to be transported from the point of delivery to the various sites.
Project Output Status quo on current traffic conditions along the envisaged haulage routes and surrounds; Road condition and safety assessment; Identify transportation related improvements in order to mitigate the potential impact of freight vehicles on the road network, including new road links, road widening, intersection improvements, changes to intersection control, road closures, one way pairs, etc.; Access location recommendations; and Transport Plan for the transportation of equipment to site.
18.4 Significance Assessment Methodology Specialists, in their terms of references, will be supplied with a standard method with which to determine the significance of impacts to ensure objective assessment and evaluation, while enabling easier multidisciplinary decision-making. The methodology17 is outlined below. The table below, taken from the above guideline, indicates the categories for the rating of impact magnitude and significance. The assessment methodology that will be used will be in accordance with the revised 2014 EIA Regulations (as amended). The significance of environmental impacts is a function of the environmental aspects that are present and to be impacted on, the probability of an impact occurring and the consequence of such an impact occurring before and after implementation of proposed mitigation measures.
18.4.1 Extent (spatial scale)
L M H Impact is localized within site Widespread impact beyond site Impact widespread far beyond boundary boundary; Local site boundary; Regional/national
18.4.2 Duration
L M H Quickly reversible, less than Reversible over time; medium Long term; beyond closure; project life, short term term to life of project permanent; irreplaceable or
17 Adapted from T Hacking, AATS – Envirolink, 1998: An innovative approach to structuring environmental impact assessment reports. In: IAIA SA 1998 Conference Papers and Notes.
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irretrievable commitment of resources
18.4.3 Intensity (severity)
Negative Positive Type of Criteria H- M- L- L+ M+ H+ Substantial deterioratio n death, Minor illness or deterioration, Moderate injury, loss nuisance or Moderate deterioration, Minor of habitat irritation, improvemen discomfort, improvemen /diversity minor change t, Substantial Partial loss of t, or in restoration, improvemen Qualitative habitat restoration, resource, species/habitat improved t, /biodiversity improved severe /diversity or managemen substitution /resource or managemen alteration resource, no or t, slight or t or very little substitution alteration disturbance quality of deterioration. important processes. Measurable No deterioratio Measurable measurabl n No measurable deterioration e change; Recommen change; Recommended Within or Measurable Measurable Quantitative ded level Recommended level will better improvement improvement will often level will never occasionally be than be violated be violated violated recommen (e.g. ded level. pollution)
18.4.4 Probability of Occurrence
L M H Unlikely; low likelihood; Possible, distinct possibility, Definite (regardless of prevention Seldom frequent measures), highly likely, No known risk or Low to medium risk or continuous vulnerability to natural or vulnerability to natural or induced High risk or vulnerability to natural induced hazards. hazards. or induced hazards.
18.4.5 Status of the Impact The specialist should describe whether the impact is positive, negative or neutral for each parameter. The ranking criteria are described in negative terms. Where positive impacts are identified, use the opposite, positive descriptions for criteria.
18.4.6 Degree of Confidence in Predictions: The degree of confidence in the predictions, based on the availability of information and specialist knowledge, is to be stated.
18.4.7 Consequence: (Duration X Extent X Intensity) Having ranked the severity, duration and spatial extent, the overall consequence of impacts is determined using the following qualitative guidelines:
Intensity = L
H
Dura tion
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M Medium
L Low
Intensity = M High H
Medium M Low L
Duration Intensity = H
H
High M Medium L
Duration L M H Extent Positive impacts are ranked in the same way as negative impacts, but result in high, medium or low positive consequence.
18.4.8 Overall Significance of Impacts Combining the consequence of the impact and the probability of occurrence provides the overall significance (risk) of impacts.
Definite Continuous H MEDIUM HIGH
Possible Frequent M MEDIUM
Unlikely Seldom L LOW MEDIUM
PROBABILITY L M H CONSEQUENCE (from Table 5)
18.5 Cumulative Impact Assessment In accordance with the EIA Regulations, consideration is also given to 'cumulative impacts'. For the purpose of this assessment cumulative impacts is defined and will be assessed in the future baseline scenario, i.e. Cumulative impact of the proposed development = change caused by proposed development when added to the cumulative baseline. In line with best practice, the scope of this cumulative impact assessment will include all operational, approved or current and planned renewable energy applications (including those sites under appeal) within a 35 km radius of the site. The renewable energy sites within 35 km of Juno WEF included in the assessment of cumulative impacts will be based on the DEA’s latest renewable energy applications for environmental authorisation spatial data. It is proposed that each of the specialists will use existing publically available information for the developments that occur within 35 km of the proposed Juno WEF in order to assess the cumulative impacts. It should be noted that this assessment will be qualitative and based on specialists’ knowledge.
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18.6 Consultation with the DEA Table 18.1 depicts the tasks to be performed as part of the EIA Process. Should the process be modified significantly, the DEA and I&APs would be notified accordingly. The rows highlighted indicate at which point the DEA will be contacted as part of the EIA Process. Table 18.1: Tasks to be performed as part of the EIA Process for the Juno WEF Task/Point of Consultation with the DEA Date
Public Review of Draft Scoping Report June 2018 Submission of Application Form to the DEA June 2018 Submission of a Final Scoping Report with the Plan of July 2018 Study for EIA Phase. DEA accepts or rejects the FSR and Plan of Study for EIA August 2018 Phase. Undertake Detailed Specialist Studies September 2018 Compile Draft Environmental Impact Assessment Report October 2018 (Draft EIA Report) and Environmental Management Programme (EMPr) for public comment based on specialist information. Advertise Draft EIA Report and EMPr for public comment October 2018 Receive public responses to the Draft EIA Report and EMPr November 2018 Submission of Final EIA Report and EMPr to DEA December 2018 Issuing of the Environmental Decision April 2019
18.7 EIA Phase Public Participation Process (PPP) During the EIA phase the following tasks will be undertaken for public participation: Notification letters to be sent out to registered I&APs, key stakeholders, and organs of state to inform them of the availability of the Draft Environmental Impact Assessment Report (Draft EIA Report) (30 days); A public event will be held in order to explain the findings of the Draft EIA Report; A Comments and Reponses Trail Report shall be compiled, recording comments and/or queries received and the responses provided. This report will be forwarded to the competent authority (the DEA), and will be included in a Final EIA Report to be released to the public for a second 30 day review period; Authorisation/Decision; Notification letters to all registered I&APs, key stakeholders, and organs of state to inform them of the decision by the DEA and the appeal procedure; and Placement of advertisements in the same local and regional newspapers (in English and Afrikaans) to inform readers of the decision taken by the DEA. Focus Group Meetings or One-on-One meetings shall be held if necessary throughout the EIA process. Furthermore, I&APs will also be able to register on the I&AP database throughout the duration of the EIA process. Once registered, I&APs will be informed about the progress of the proposal.
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APPENDIX A: EAP CV AND COMMISSIONER OF OATHS
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APPENDIX B: PUBLIC PARTICIPATION 1. Landowner and Surrounding Landowner Notifications 2. Site Notices and Poster Placement 3. Newspaper Adverts 4. Key I&AP Notifications 5. I&AP Database 6. Comments and Responses Trail 7. Correspondence 8. Notification of Availability of the Draft Scoping Report for Public Review 9. Proof of Delivery of the Draft Scoping Report 10. Public Meeting – Scoping Phase
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